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<br /> <br />2.NECC should evaluate the currently approved vegetation sampling methodology for applicability <br />to the current permit conditions. Please assure that any sample methodology changes meet the <br />requirements of Rule 4.15.11. Division guidelines (Guidelines regarding Selected Coal Mine <br />Bond Release Issues, 4/18/1995) may provide assistance in determining appropriate sampling <br />design for small areas. <br /> <br />The permit does not define how much topsoil is to be replaced on the reclaimed NW Bleeder Shaft <br />location. No confirmation of topsoil replacement thickness was included in the 2004 ARR. No <br />discussion of topsoil replacement was included in the SL4 application: Phase I bond Release for sealing <br />and regrading of the NW Bleeder shaft. <br /> <br /> DRMS inspection report 12/7/2004: documents that at the time of sealing of the NW Bleeder <br />Shaft two topsoil piles were inspected at the NW Bleeder Shaft site. These were to be used in the <br />reclamation of the shaft pad. <br /> <br /> DRMS inspection report dated 1/25/2005: documents that all reclamation work at the NW <br />Bleeder Shaft had been completed at the time of the inspection. Photos document that the area had been <br />regarded and mulched. No mention was made of topsoil application. <br /> <br />No topsoil piles remain on the NW vent fan site (2012). DRMS assumes that all topsoil available at the <br />NW Bleeder Shaft were utilized during the reclamation of the fan shaft and pad. <br /> <br /> <br />3.The Division requests that NECC provide documentation of the volume of topsoil replaced at the <br />NW Bleeder Shaft reclaimed pad area. <br /> <br />The approved reclamation is in agreement and supports the approved post-mining land use of rangeland. <br />2 <br />