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17. "Grassland Reference Area -He needs to report the refuse pile against the grassland reference area. <br />Where is it located in relationship to the refuse pile ?" <br />Answer: The Grassland Reference Area is identified as Reference Plot "A" on Map 16. The Grassland <br />Reference Area is located north of the coal refuse area. TR39 is not proposing any changes to this <br />reference area. Please see the response to #16 regarding the Interim monitoring reports. <br />18. "2010 Revegetation Report -Also the 2010 report had fewer transects. What is with that ?" <br />Answer: The year 3 (2006) and year 7 (2010) Interim Revegetation Monitoring reports were permit <br />requirements to evaluate trends observed on the reclaimed areas. These reports were not intended to <br />be used for determination of reclamation success, nor will they be used for such purpose. These reports <br />simply document the status of the establishing vegetation on the reclaimed areas. They are not part of <br />the TR39 evaluation. <br />19. "Source of Topsoil -What was the source of the topsoil used for the portal and pond area? I know that the <br />barrows area provided the topsoil for the refuse pile. Based on this can it be 4 feet deep ?" <br />Answer: Topsoil salvage and replacement is not a topic specific to TR39. <br />Permit section 2.05.4 discusses which topsoil stockpiles were used to reclaim specific portions of the <br />mine. Bond Release No. 2 also verified the thickness of cover material on the refuse pile. The Findings of <br />Compliance and Proposed Decision for Phase I Bond Release and Bond Reduction SL -02, dated April 23, <br />2003, documents that at Ms. Sunders request, dated November 9, 2002, the Division had Energy Fuels <br />dig three additional confirmation holes to document the topsoil and refuse pile cover depths at both the <br />portal area and the refuse pile. The cover depths had also been documented in previous Division <br />inspection reports and independent engineer's reports. The Division selected the hole sites with Ms. <br />Saunders. All three holes were dug using a backhoe to a minimum of four feet deep. All three holes <br />confirmed that cover depths at the facilities area (portal area) and refuse pile to be in compliance with <br />the approved permit. <br />20. "Also is the barrows area included in the total size of the refuse pile calculation ?" <br />Answer: The Division believes the reference to a barrows area is referring to the topsoil borrow area <br />located immediately to the west of the Coal Refuse Area. This question is not specific to TR39. The Coal <br />Refuse Area for purposes of sampling includes the topsoil borrow area. <br />21. "2010 Revegetation report- Kent's 2010 report states that the total herbaceous production was not <br />achieved on the Vento reclamation. Why not ?" <br />Answer: Production results during the 7 th year of vegetation establishment are not specific to TR39. <br />The interim vegetation report is not intended to establish reclamation success achievement but to <br />document the revegetated areas trend towards reclamation success. The reclamation area has an <br />additional three years of vegetation growth and establishment before the area will be eligible for the <br />permittee to document that it has achieved the reclamation success standards (2013 at the earliest). <br />22. "How can an increase in rabbitbrush from 26.57% in 2006 to 53.33% in 2010 not be substantial (forget <br />the t score statistical test)." <br />