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C- 2010 -089 NHN Mine <br />PAR No. 2B <br />20- Oct -2011 <br />Page 4 of 7 <br />c) A black line is used to delineate the "existing reclamation / disturbance boundary ". <br />This line is discontinued across the western and northern limits on the Garvey property. <br />Please complete the outline of the areas previously reclaimed. <br />2.05.4(2)(c) — Backfilling and Grading <br />6. In the introductory paragraph, please add a statement that this section addresses the <br />requirements of 2.05.3(6), 2.05.4(2)(c) and 4.14. <br />2.05.4(2)(d) — Topsoil Redistribution <br />4. The first sentence of the Introduction to Section 2.05.4(2)(d) states that the section outlines <br />WFC's plan to meet the requirements of Section 2.05.4(2)(d). It appears that the <br />requirements of 2.05.3(5) and 4.06 are also intended to be addressed here — please revise the <br />text to include these two sections, if appropriate. <br />5. The 2.05.4(2)(d) Introduction explains that "a sufficient thickness of suitable backfilled <br />weathered overburden material is replaced as subsoil... and that a minimum of <br />approximately three to four feet of suitable plant growth material, including the available <br />topsoil, exists on the surface of all regraded lands..." The text does not appear to commit <br />the applicant to placement of any specific minimum thickness of topsoil in the upper portion <br />of the "suitable plant growth material ". Please revise this paragraph to be consistent with <br />any topsoil (and subsoil) replacement changes made in response to the Division's adequacy <br />items that follow. <br />6. The outline used for Section 2.05.4(2)(d) appears to emulate that used for the New Horizon <br />Mine permit. For clarity, please insert the header "Overburden / Spoil Handling Plan" in <br />front of the "New Horizon North Mine Overburden and Interburden Characteristics" <br />subsection on page 1. <br />7. The first paragraph on page 2 refers to "Appendix 6 -4... Volume A, 1993" of the New <br />Horizon Mine permit for a description of the interburden at NHN. This reference does not <br />appear to be applicable to the existing version of Permit No. C- 1981 -008 — New Horizon <br />Mine. Please include any referenced permit materials within the NHN application. <br />8. The first complete paragraph on page 3 describes the mine sequence, and states that, <br />"topsoil, subsoil, or mixed" soil will be removed first. The text which follows should be <br />modified to include the possibility that soil will be stockpiled. <br />9. In the sixth line of the first paragraph on page 3, please delete the words, "As described in <br />Small Area Exemptions ". <br />10. The first paragraph of the Regraded Subsoil Backfill Material Monitoring Program <br />subsection (page 4) mentions inspecting for compaction and slippage potential. These <br />problems would seem to be unlikely, if ripping is conducted as described on page 6. Please <br />clarify whether the inspection will be done prior to, or following ripping. The last sentence <br />of this paragraph lists various parameters that will be analyzed. Please include a reference <br />to where in the permit the suitability criteria may be found. <br />