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INTEROFFICE MEMORANDUM <br />TO: JASON MUSICK <br />FROM: JANET BINNS <br />SUBJECT: LORENCITO CANYON MINE C1996 -084, RN3 ADEQUACY REVIEW <br />DATE: 7/6/2012 <br />CC: <br />I have reviewed the Lorencito Canyon Mine permit for compliance with Rules: <br />2.04.9, 2.04.10, 2.05.4, 2.05.5, 4.06, 4.015, and 4.16. <br />I have also looked at supporting Annual Reclamation Reports, and inspection reports. <br />I have the following concerns: <br />1. Is there one map that shows all the approved culverts? Along the access road and <br />the sediment pond access roads, there are approved culverts that are NECC's <br />responsibility and have been designed for specific flows. On the ground, <br />additional culverts have been installed by a third party (oil and gas development) <br />and are not NECC's responsibility for maintenances. I have been unable to locate <br />a map with all of the culverts on it, that defines which culverts are NECC's <br />responsibility and which are not. This map would need to be specific to the actual <br />area of disturbance for the Jeff Canyon Surface mine. If one does not already <br />exist in the permit, NECC needs to provide a single map that provides this <br />information. <br />2. NECC is considering using topsoil substitute material for gully repair locations. <br />The permit currently does not describe use of alternate plant growth material. <br />NECC needs to describe this practice in the permit. In this description NECC <br />needs to describe where the substitute material would come from, and describe <br />what soil chemical and structural parameters the topsoil substitute will b tested <br />for. Suggested parameters to demonstrate topsoil suitability include; N, P, K, <br />SAR Electrical conductivity, Soil texture, and Organic Matter. <br />3. Permit page 2.05 -63 states that, "contour furrows may be employed along the <br />steeper slopes of highwall reclamation areas." Several areas on the reclaimed <br />slopes at the Lorencito Canyon Mine continue to exhibit gully formation. NECC <br />plans to conduct gully repair on these slopes in 2012. The Division considers <br />implementation of contour furrows or straw bale dikes as approved in the permit <br />appropriate to the repair efforts. Please utilize approved erosion control methods <br />in accordance with NECC's approved reclamation plan. <br />4. Page 2.05 -60 of the Revegetation Plan commits NECC to, "monitoring will be <br />conducted to identify potential problems with vegetation." The permit does not <br />