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applicant to be aware of the stability and bonding concerns associated with this mining <br />method that have been identified. It is likely that these concerns can be addressed <br />through mining modifications, special material handling methods and increased bonding <br />if necessary. <br />The division will wait for the results of the stability analysis to address this further. <br />6.4.5 EXHIBIT E -Reclamation Plan <br />Overall, the reclamation plan appears to be fairly straight forward. Some concerns with <br />the plan have already been identified, including backfill placement and stability and <br />topsoil re-application depths. The backfill placement and stability should be addressed <br />with the geotechnical stability exhibit. In addition, it appears that the operator intends to <br />backfill with material imported from off-site. If that is the case, the operator will also <br />need to identify the source of this material and certify that it will be inert in accordance <br />with the definition of "Inert Material" included in Rule 1.1(20). In addition, once the <br />general nature of the fill material that will be used has been identified, a general <br />engineering plan stating how the material will be placed and stabilized to avoid settling <br />and voids should be submitted for inclusion in the final reclamation plan. The topsoil re- <br />application depth should also be increased to a range of 12-18 inches as discussed under <br />Exhibit D. <br />One area that was not discussed in the reclamation plan is the necessity for a noxious <br />weed control plan. The fact that the land is in agricultural production indicates that there <br />is very likely a presence of some noxious weeds on the site. Rule 3.1.10(6) requires that <br />methods of weed control shall be employed for all prohibited noxious weeds. In addition, <br />the division recently developed a policy memorandum concerning the control of noxious <br />weeds. As a result, a noxious weed control plan should be included with the permit <br />application that includes at a minimum: target weed species (this can be obtained from <br />the local weed control district), methods of treatment (it is a good idea to include several <br />such as spraying, mowing, grazing, burning, bio-control, tillage, etc.), treatment <br />windows, and follow-up monitoring. It is especially important to keep topsoil stockpiles <br />and product stockpiles free of weeds so that they do not get spread around the site or <br />transported off the site. <br />The post-mining land uses should be consistent throughout the permit document. The <br />application indicates that the primary post-mining land use will be general agriculture, <br />however, in Exhibit D it is stated that pastureland is apost-mining land use and then <br />under Exhibit E it includes rangeland and open bodies of water. This may seem to be a <br />rather picky point, however, when it comes time for final financial and performance <br />warranty release, the site must be reclaimed in accordance with the approved post-mining <br />land use. If there is a conflict about what that is, it can become rather cumbersome to <br />unravel. Therefore, please clarify what the post-mining land use is and refer to it <br />consistently throughout exhibits and application. <br />