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2009-01-02_REVISION - C1980005
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2009-01-02_REVISION - C1980005
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Last modified
8/24/2016 3:39:25 PM
Creation date
1/6/2009 10:53:37 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1980005
IBM Index Class Name
REVISION
Doc Date
1/2/2009
Doc Name
Adequacy Review
From
DRMS
To
Seneca Coal Company
Type & Sequence
SL3
Email Name
DTM
Media Type
D
Archive
No
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standard, it would be appropriate for sample adequacy to be demonstrated based <br />on herbaceous cover, as well as total vegetation cover. <br />Please address this concern, and unless appropriate justification is provided, <br />please commit to timely revision of the approved permit to specify that <br />sample adequacy will be demonstrated for herbaceous cover, in addition to <br />total cover, in future Phase II or Phase III bond release applications. <br />3. The Division noted that in t-test demonstrations of success for BRB-4, the sample <br />standard deviation for total vegetation cover was used, rather than the sample <br />standard deviation for herbaceous vegetation cover. Because the sample mean for <br />herbaceous cover is used in the t-test to demonstrate cover success, it is <br />appropriate that the sample standard deviation for herbaceous cover, rather than <br />total vegetation cover, be used as well. <br />Please address this concern, and unless appropriate justification is provided, <br />please commit to timely revision of the approved permit to specify that <br />herbaceous cover sample standard deviation will be used in hypothesis <br />testing for future Phase II or Phase III bond release applications. <br />4. On page 15 of the SL-3 application, SCC addresses permanent impoundments. <br />Under the Permanent Impoundment Documentation heading, information <br />regarding approval of existing sedimentation ponds as permanent impoundments <br />was provided, but no such information was provided regarding approval of <br />existing stock ponds as permanent impoundments. <br />Please provide information regarding approval of existing stock ponds as <br />permanent impoundments, consistent with the information provided <br />regarding sediment ponds approved as permanent. <br />We note that in Appendix 13-9 "Permanent Stock Pond Evaluation" of the <br />approved permit, SCC states that "water sampling conducted during the bond <br />release period will be used to confirm [the assumption that water quality will be <br />suitable for the intended use]". Please take note that water quality suitability <br />demonstrations (for livestock/wildlife use) similar to those provided for <br />permanent sedimentation pond impoundments, will be required for Phase III <br />bond release, for each permanent stock pond. We recommend that samples <br />be obtained, analyzed, and suitability demonstrations be submitted for <br />Division review and acceptance as soon as this field season, to ensure that <br />demonstrations are finalized prior to Phase III application submittal. <br />4
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