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October 20, 1980 ! , Department of Natural Resources , Re: MLRB File No, 80-47 Page Two (b) Topsoil stockpiles must be constructed so as to minimize surface acreage disturbance and stockpile fosses due to erosion. (c) The operator will conduct investigations on native f~rb establish- ment in conjunction with studies to be carried out on experimental vegetation plots representative of actual embankment conditions. The purpose of the experimental plots will be the further refinement of the reclamation plan and to conduct onsite reclamation studies to evaluate the depth of soil cover required to attain the reclamation objectives set forth in the application, If these studies indicate the operator's objectives can lie adequately met with a different thickness of soil cover than is required by 1 (a) herein, these requirements will be amended accordingly. In addition, the operator will encourage commercial seed production of native forb species by cooperating with commercial seed growers and the t.eeker and Las Lunes Plant Paterials Centers, and other sources. (d) Prior to the usage of any soil amendment or enhancemen*_ materials, the operator will provide the Division with adequate proof that the appropriate agencies of the state and federal government have, where necessary, approved utilization of said material. In the event no such approval is required, by any other government agency, the operator will complete mutually acceptable chemical analyses appropriate to aid the Division in reviewing its suit atility for such use. For the purposes of this provision, fertilizers and mulched vegetation shall not be deemed or considered soil enhance- ment or amendment materials. (e) The operator will monitor for the presence of trace elements in vegetation. The term "trace elements" will include, but not be limited to, the following: arsenic, boron, molybdenum and selenium. Monitoring will be conducted periodically during each growing season. The general objective of this monitoring will be to in- vestigate the effects of trace elements on plant lifts and grazing animal life. Monitoring will take place in two (2) stages. Stage I monitoring will be conducted on test plots grown on soil stock- piles. The purpose of this monitoring will be to establish naturally occurring levels of trace elements in vegetation. Stage II monitoring will be conducted, as soon as practicable, on test plots in reclaimed areas on the spent shale disposal site. Monitoring data and reports will be available for inspection by the staff onsite. The operator may petition the staff to curtail or eliminate any stage of monitoring. (f) Monitoring will be conducted to evaluate the concentration and the migration of soluble salts within the spent shale. Should any salt crust form on the surface of the spent shale disposal pile, it will be analyzed to determine its chemical composition. (This provision also addresses concerns raised by Mr. Roy Cox in his memorandum of October 9, 1980 to Mr. James McAtdle).