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C-1981-008 - SL-12 <br />Adequacy Review No. 4 <br />5 May 2011 <br />Page 4 of 10 <br />4. The cover table in Appendix B of the Phase II Vegetation Sampling report is a working spreadsheet. It <br />provides all of the necessary data to allow for statistical calculation and technical evaluation; however a final <br />summary table needs to be included in the report. The summary table should be of the general form provided <br />in Attachment 1 to this memorandum. The purpose of the table is to provide a clear and accessible summary <br />of the cover and composition of the sampled parcel. The table should list each plant species by common and <br />scientific name, a column for relative vegetation cover by species, a Total Vegetation Cover Column, and the <br />"Total Desirable" Column. Please provide a Summary Cover table, in the general form requested. <br />WFC provided the requested table with Aug. 2010 submittal. Item resolved. <br />5. In accordance with the bond release guideline (p. 5), please provide a narrative summary of the reclamation <br />and management history of the parcels included in the Phase II release request. <br />WFC's Aug. 2010 response provided the requested information in text and tabular forms within the <br />application narrative, and depicted the data graphically on Map R-1. The Division notes one discrepancy <br />regarding reclamation of the Benson parcel. As illustrated in the New Horizon Mine 2007 Annual <br />Reclamation Report (Exhibit 2007-06), an area of 7.7 acres was re-topsoiled and re-seeded in 2007. Please <br />revise the Phase 2 Area I topsoil information on pages 9 and 10 of the application text to refer to 2007 <br />rather than 2006, and incorporate the 2007 area into Map R-1. <br />WFC's Aug. 2010 response did not provide sufficient management details for the Irrigated Pasture. This <br />item was elaborated upon in the Division's March 9, 2011 review, and successfully addressed in WFC's <br />March 17, 2011 response. Item resolved. <br />6. Please provide specific information regarding topsoil/subsoil replacement requirements and thicknesses <br />applicable to the Phase II release parcels, and provide narrative explanation (based on sample data) to <br />support the conclusion that the required replacement thickness was achieved. List the soil thickness sample <br />points on Map R-1 that fall within the Phase II release areas, along with the thickness measured for each <br />point. All of the soil thickness sample points within the Phase 11 area must list a measured soil thickness; <br />please provide any missing data. <br />WFC's Aug. 2010 response did provide additional details regarding topsoil replacement thicknesses and <br />required thicknesses. In its March 9, 2011 review, the Division initially indicated that the response provided <br />was acceptable. However, upon closer review, the Division finds that certain information presented in the <br />Phase 2 Area - Topsoil Thickness Samples Table on page 27 may not be correct. <br />Phase II Area 2 (WFC parcel) was incorporated into the permit with PR-04 in October 1996. Phase II Area <br />1 (Benson) was permitted under PR-05 in April 2000. A review of the required topsoil replacement <br />thicknesses for the SL-12 Phase II bond release areas reveals a puzzling history of alterations having been <br />made to Map 2.05.4-4 - Topsoil Replacement. <br />Subsequent to the approval of PR-05, Map 2.05.4-4 was modified for permit areas east of 2700 Road by MR- <br />51 (in Oct-2001) and/or TR-54 (in Jul-2007), by TR-57 in Mar-2009, and by PR-06 in Dec-2010. A <br />summary of the changes, for each topsoil sample point pertinent to the Phase II SL-12 application, is <br />provided in the table below. <br />For areas northeast of the BB12700 Road intersection, the varying thicknesses for topsoil replacement blocks <br />was abandoned with MR-51, as has been noted by the Division in previous correspondence. This change <br />was perpetuated through the approval of TR-54 in July 2007. <br />The main purpose of TR-57 was to update the permit to address topsoil salvage and handling for prime <br />farmlands west of 2700 Road. No changes to topsoil replacement thicknesses east of 2700 were proposed by <br />WFC or reviewed by the Division with TR-57, as topsoil redistribution and seeding had been already