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Seneca II-W Mine; C1982057 SL5 Application Adequacy Review No. 1 September 4, 2013 23 Page of percentages need to be revised, please do so and update the success standard for vegetation cover accordingly. 6. In accordance with Tab 22, Page 44 of the permit, for the South Extension Area, the applicable extended reference area will be those portions of the South Extension Area permit area not to be affected by mining. For revegetation success comparisons for SL5, only the northern portion of the permit area were sampled and used for the extended reference area. Undisturbed portions of the South Extension Area were not sampled as the extended reference area to be used as a comparison for Phase II bond release parcels within the South Extension Area as required in the permit. The Division believes the sampling conducted in each vegetation type in the northern extended reference area is likely representative of the same vegetation types found in the extended reference area in the South Extension Area. The pre-mine percentages of each vegetation type may be different; thus impacting the weighted success standard. This issue is addressed in the adequacy review item above. However, SCC should be aware of this permit requirement for future bond release applications. 7. The SL5 bond release application included an analysis of species diversity and composition based on the incorrect 2012 Revegetation Monitoring Report, thus the results are invalid. The correct 2009 revegetation monitoring report did conduct sampling for species density which is used to judge species diversity for the reclaimed area; however an analysis was not conducted of this data. Please conduct an analysis of species diversity based on the correct revegetation monitoring data and provide the Division with the results and a discussion of the analysis and revise the bond release application accordingly. Water Quality – Total Suspended Solids (TSS) Monitoring Results 8. The ponds receiving runoff from the proposed bond release area have not been approved for permanent retention because SCC does not yet have the approval of the State Engineer. As part of a Phase II bond release, we are required to make a finding, under Rule 3.03.1(3)(b), that the areas proposed for release are not contributing suspended solids in excess of pre-mining levels or adjacent non-mined areas, so that sediment control structures that are not permanent could be removed. Since the ponds receiving runoff from the disturbed areas are not permanent, the Division will need additional information to assist us in determining whether the area meets the requirements of Rule 3.03.1(3)(b). a. SCC submitted pond discharge sample data for all the ponds receiving discharge from the proposed bond release area with the exception of Pond 005. Please provide the sample data for Pond 005. b. SCC indicates on page 8 of the application that the receiving streams upstream of the confluences have significantly higher Total Suspended Solids (TSS) than the discharge from the Phase II release area. However, SCC did not cite any documentation as a basis for the statement or submit sample data from the receiving streams. SCC did submit sample data from the NPDES discharge points for the years 2008 to 2012 (with the exception for Pond 005). In the 2008 to 2012 Annual Hydrology Reports, the Division found TSS sample data from monitoring sites upstream and downstream of the confluences of the discharges from Ponds 005, 006, 016 and 017. However, the Division could not locate sample data for points upstream of discharge points 015 and 009 during the same sample years for a comparison. For the receiving stream upstream of discharge points 015 and 009, please provide upstream sample data for TSS. Without this information it cannot be found that the discharge from the reclaimed area is less than upstream flow. 9. The use of sediment pond discharge data to determine the level of suspended solids generated from the reclaimed area is somewhat limited in that it gives information on the performance of the pond in treating runoff but does not give any indication of the sediment levels coming off of the reclamation. To better ascertain the levels of sediment being generated on the reclamation area, we need the following: