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ability to support and enhance rangeland and wildlife, and described in permit section 2.05.5. A soil <br />loss demonstration for the reclaimed disturbed area has been incorporated into subsection 2.05.3(4) <br />of the permit as approved in Technical Revision No. 10 and Minor Revision No. 11. James E. <br />Stover, P.E. provided a notarized statement dated October 29, 2009 certifying that all applicable <br />reclamation activities performed at the Hamilton Mine, mining permit C-1991-078, have been <br />accomplished in accordance with the requirements of the Act, the Rules, and the approved <br />reclamation program. <br />III. OBSERVATIONS AND FINDINGS <br />PHASE Il <br />A. Topsoil Replacement <br />Topsoil salvage for the Hamilton Mine is described in permit section 2.05.3(5), and detailed <br />information about the topsoil inventory and laboratory analyses is found in Exhibit 7. <br />Baseline data suggested that an average of 10 inches of topsoil was available for salvage and <br />replacement in Mining Area No. 1, and 16.4 inches was available in Mining Area No. 3. A <br />description of topsoil handling (and replacement) is provided in section 2.05.4(2)(d) of the <br />permit. Topsoil redistribution in Mining Area No. 1 occurred in 1992 and 1993. Mining <br />Area No. 3 was topsoiled in 1993. <br />Prior to topsoil replacement, the upper three feet of regraded overburden was to be sampled <br />for subsoil suitability on a 300' grid, as described in section 2.05.3(6) of the permit. Permit <br />Drawing 135A shows the locations of 25 subsoil sampling pits dug within Mining Area No. <br />1. No subsoil sampling sites were identified for Mining Area No. 3. Subsoil analysis results <br />are presented at the end of Exhibit 7, in the Soils Analysis Summary. <br />During the Division's 1994 Midterm Review of the permit, two questions were raised <br />regarding topsoil replacement: 1) Did the operator conduct the required sampling of the <br />topsoil after replacement and prior to reseeding, and 2) After the topsoil was reapplied, did <br />the operator or the Division verify the depth to confirm compliance with the approved plan? <br />Topsoil handling and replacement is described in permit section 2.05.4(2)(d). According to <br />the text, "Nutrients or other soil amendments will be applied to the redistributed topsoil if <br />shown to be required by soil tests... Soil will be tested for pH, phosphorus, potassium, <br />texture class, electrical - conductivity, sodium adsorption ratio, and nitrogen. Section <br />2.05.4(2)(e), Revegetation, goes on to say, "At the time of seeding, fertilizer will be applied <br />to enhance root development in the range mix seedlings" and, "At the beginning of the <br />second season of growth for the range seedlings, nitrate fertilizer will be applied... <br />according to the rate indicated by soil analysis." The permit does not require that results of <br />topsoil testing be submitted to the Division, and the Annual Reclamation Reports do not <br />address the subject. <br />Based on Division records, it appears that neither Honeywood nor the Division had <br />previously verified the depth of topsoil redistribution following reclamation activities at the <br />4