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7. The applicant states on page 6 that as mining is completed, backfill will be placed against mined slopes as part of concurrent reclamation; and on page 14 that the acreage of disturbed areas equals 33.2 acres (24.4 disturbed, plus 8.8 slope). Review of the Mine Plan Map, Exhibit C-3 indicates the following affected areas and acreages: plant, processing, batchplant, and stockpile areas (6.9 acres); Cell 1 (2.8 acres); Cell 2 (20.8 acres): Cell 3 (7.2 acres); Cell 4 (37.6 acres); and wetland mitigation area (13.9 acres). In conformance with Rule 6.4.4(d), please clarify the maximum disturbance to be expected at any one time throughout the life of the operation. Such maximum disturbance should include areas and volumes of pit disturbances assuming near vertical malls, volume of overburden to be generated and stockpiled, volume of topsoil to be salvased and stockpiled, lengths of pit walls that have been backfilled and graded [o finish contours, lengths of backfilled R graded pi[ walls and/or acreages of affected land that have been topsoiled, acreage of land requiring revegetation, and the plant site area. Such maximum disturbance is needed to calculate an appropriate and accurate reclamation cost. As an alternative, the applicant may indicate the entire affected land acreage will be disturbed and provide a reclamation cost estimate adequate to reclaim such disturbance. Please address. 6.4.5 EXHIBIT E -Reclamation Plan 8. The applian[ indicates on page 14 that [here will be excess overburden generated during the minim process. The Division requests that the applicant clarify [he volume of overburden needed for backfilling and grading [o produce [he desired reclamation contours at a time of maximum disturbance as defined in item 7 above. An itemized cost for backfilling and grading of such volume should be included in the Reclamation Cost Estimate, Exhibit L. (In the event there is an excess of overburden generated, the applicant can either provide an additional reclamation cost for backfilling the excess into [he pit area(s) or commit to stockpiline no more than the volume of overburden needed for backfill and grading during a maximum disturbance scenario). Please respond. 9. The applicant indicates on page 14 that there will be excess topsoil generated during the mining process. The Division requests that the applicant clarify the volume of topsoil needed for reclamation at a time of maximum disturbance as defined in item 7 above. Please respond. 10. The applicant had ajurisdictional wetlands delineation performed on the Green/Croissant Property in July 2000 by Savage & Savage. Inc.. The results of the delineation indicate that jurisdictional wetlands account for 30.7 acres and waters of the U.S. account for 5.~1 acres within the proposed permit area. Review of the Reclamation Plan Map, Exhibit F shows a reclaimed wetland of 8.3 acres, a potential wetland enhancement area (also shown on Exhibit C as a potential wetland mitigation area) south of Cell 3, a potential wetland enhancement area south of Ce114, and a po[enial shelf for emergent wetland mitigation along the west edee of Cell 4. The applicant also indicates on pages 6 & 7 that some wetlands presently existing in Cells 3 & 4 are believed to have been caused by improper maintenance of tailwater ditches, that these ditches wtll be improved during initial mining operations, and that a new delineation may occur prior to mining these areas. The Division is in agreement with the applicant that a 404 Permit (or other permit as required by the Corps of Engineers) would be obtained prior to mining in any existing jurisdictional wetlands. However, the information referenced above is somewhat confusing. The Division has several concerns with respect to mining within existing jurisdictional wetlands and wetlands reclamation within [he permit area. Firs[, the applicant should clarify the location and acreage of existing jurisdictional wetlands and waters of the U.S. that will be disturbed during the mining operation. The applicant may revise Exhibit C-2 or C-3 to show the location of such wetlands and waters (30.7 & ~.~1 acres) as mapped in the July 2000 Savage & Savage, Inc. wetland delineation. Or, the applicant may commit to submittal of a revised wetlands