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within Phase 1 Bond Release SL-4. Please include reference to SIIPM-13 in the bulleted <br />list, and delete the statement indicating that the channels would become permanent <br />features in the future (since they are already approved as permanent). <br />2.05.4(2)(e) <br />11. On page 2.05.4-2 of the PR-2 application volume, there is a subsection titled "Revegetation <br />Monitoring". The narrative within the section does not actually address interim revegetation <br />monitoring, but rather includes one brief paragraph and a separate sentence at the end of the <br />subsection that pertain to methods for demonstrating revegetation success for bond release, and <br />an additional paragraph that pertains to revegetation chronology. Quantitative interim <br />revegetation monitoring at Seneca II has been phased out, as the emphasis has shifted to <br />sampling for demonstrations of success for Phase II and Phase III bond release. The <br />revegetation monitoring section of the permit application package was updated with TR-50 in <br />2009, to reflect this shift in emphasis. The "Revegetation Monitoring" subsection heading in <br />the PR-2 volume should be deleted, along with the confusingly written 1St paragraph of the <br />subsection and the unnecessary final sentence of the subsection. The second paragraph of the <br />subsection should be retained, under a subsection heading "Revegetation Chronology". Please <br />amend the narrative as warranted. <br />12. The introductory paragraph to the subsection titled "2.05.4(2)(e)(vi) Determining Revegetation <br />Success" contains erroneous references to regulation sections 4.15.9 and 4.15.10 that do not <br />apply to the Seneca II permit area proposed in PR-2. Please delete the erroneous references. <br />13. The third paragraph of the "Determining Revegetation Success" subsection includes an <br />unnecessary, confusing, and outdated reference to revegetation monitoring, which would be <br />conducted "in the third or fourth, ninth and tenth year following permanent seeding...". The <br />entire first sentence of the paragraph should be deleted; interim quantitative monitoring is no <br />longer required under the approved permit, and the 9th and 10th year sampling reference is also <br />dated (current regulations allow success demonstration sampling in the final four years of the <br />liability period, beginning no earlier than year 9, as correctly noted in Appendix 13-13 of the <br />approved permit). Please amend the narrative as warranted. <br />14. Vegetation sampling bond release blocks, sampling methods, and associated statistical <br />procedures for demonstrations of revegetation success are currently addressed in <br />comprehensive fashion within Appendix 13-13 of the approved application package. However, <br />Subsection 2.05.4(2)(e)(vi) of the PR-2 volume, beginning with the second paragraph of the <br />subsection on page 2.05.4-2, describes certain approaches and methods that differ substantively <br />from those specified in Appendix 13-13, in at least two instances. The PR-2 narrative includes <br />a proposal to base success for cover and production using only the "sagebrush grassland" <br />reference area, rather than an acreage weighted comparison to "Mountain Brush/Aspen" (83%) <br />and "Sagebrush" (17%). Note that the current Seneca II permit does not identify a "Sagebrush <br />Page 4 of 7