Laserfiche WebLink
C- 1991 -078 <br />SL -02 Review <br />27 May 2010 <br />Page 2 <br />permit. The report also includes projected soil salvage volumes and thicknesses for the various <br />r r <br />mining areas. <br />The Division has reviewed the SL-02 application and supplemental reports. In addition, we have <br />reviewed the various sections of the approved permit application related to soil and vegetation, <br />requirements, and the most recent renewal findings document (RN-03 findings, dated <br />3/13/2007). <br />We have a number of review comments, which are itemized below. There are significant flaws <br />in the application related to vegetation cover success demonstration, that would appear to <br />disallow approval of the requested Phase II bond release. These flaws are addressed in <br />Adequacy Item #1, below. <br />1. <br />Rule 3.03.1(2)(b) states 'that up to 85% of the applicable bond arnount shall be released <br />upon the establishment of vegetation which "supports the approved post mining land use <br />and which meets the approved success standard for cver,...based on statistically valid <br />data collected during a single year of the liability period ". Narrative in Item #16 <br />(description of results achieved) of the original SL -2 application submittal, states that <br />"the enclosed vegetation study... shows the reclaimed nine site has better plant cover <br />than the undisturbed adjacent areas and the reference areas. Therefore, vegetation on the <br />reclaimed mine site meets the approved success standard for coven and supports the <br />approved postmining lard use of rangeland and wildlife habitat ". <br />The CCA vegetation report does contain information indicating that reclaimed area cover <br />within a major portion of th ,site (Mine Area 1 is likely to meet or exceed the reference <br />area cover success standard. However, the Division finds that the report does not provide <br />(nor does it purport to provide) a statistically valid demonstration of vegetation cover <br />success, which is required for Phase II bond release approval. This finding is based on <br />the -follo in reasons: <br />a used on vegetation Map 1 included in the CCA report, the revegetation "sample <br />universe ", was limited to the main portion of Mining Area # 1, and did not include <br />Dining Area #, or the three small ancillary facility areas located south of the <br />mining areas; <br />b The CCA report includes narrative, charts and tables which show the likelihood <br />that cover success was achieved within the sampled reclamation area, but the <br />report: describes the sampling as "monitoring in the interest of ascertaining <br />progress ... ", and notes that sample size was restricted "due to managerial nature <br />of collected data. ", 'The report cues not .state or imply that the sampling was <br />conducted to provide statistically valid data for bond release demonstration. <br />C) Sample adequacy was evaluated for the one reclaimed unit and various reference <br />area units "for informational purposes ". Minimum sample size of 15 was not <br />achieved for either of the two separate sagebrush reference areas or the split <br />grassland reference area, and transects were not proportionally allocated within <br />