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Requirement <br />Rules <br />Permit (PR 6) <br />Specific Requirement <br />Information Provided /Source /Details on Requirement <br />Division comments <br />24 <br />Annual Reporting, Permit page <br />Topsoil Thickness - Soil lift <br />Exhibit 2011 -6 depicts <br />Evaluated Attachment 2011 -A sample results in comparison to threshholds in Table 2.05.4(2)(d) -lB and in Section 2.05.4(2)(d) 2011 -03 MR79 for samples (TS- <br />2.05.4(2)(e)-74; Permit (PR 6 MR <br />thickness data and soil and topoil <br />topsoil thickness and sample locations, Attachment 2011 -A consists <br />104, 105, 106, 107 and 108). THE ACCEPTED SOIL TEXTURES IN TABLE 1B DO NOT APPEAR TO INCLUDE SCL (SANDY CLAY LOAM), WHICH IS THE TEXTURE <br />79) section 2.05.4(2)(d) - Table <br />sampling reports and data <br />of required soil samples taken by WFC personal. <br />INDICATED IN THE SAMPLE RESUTLS FOR ALL SAMPLES. DOES "SC" IN TABLE 1B ENCOMPASS "SCL "? PLEASE VERIFY. Evaluated Exhibit 2011 -6, topsoil, 5 sample <br />2.05.4(2)(d) -lB Spoil and Soil <br />pursuant to Section 2.05.4(2)(d) <br />points were sampled in the 6.8 acre topsoiled area in Zone 7 (meeting the requirement of 1 sample per 5 acres in this area, correct grid dimensions are shown <br />Suitability Criteria (Other Areas) <br />and Tables 2.05.4(2)d) -lA and 1 B ; <br />on the map). Evaluated exhibit 2011 -6 soil samples in comparison to thresholds in Table 2.05.4(2)(d) -16 and in Section 2.05.4(2)(d) 2011 -03 MR79. TOPSOIL <br />Topsoil testing and reporting per <br />DEPTH REQUIREMENT FOR ZONE 7 IS 12 -20 ". TABLE 1B INDICATES THAT THE SAMPLE THICKNESS SHOULD BE A MAX OF 2'. SAMPLE TS -105 HAD A DEPTH OF <br />Section 2.05.4(2)(d) <br />24 ", EXCEEDING THE REQUIRED RANGE OF 12 -20 INCHES. IS THIS EXCESS ACCEPTABLE? ASSUMING COLUMNS WERE INTERPRETED CORRECTLY BASED ON <br />CURRENT BLACKED OUT VERSION, all samples tested within threshholds, NOT INCLUDING TEXTURE, SEE ABOVE NOTE. <br />25 <br />Permit section 2.05.4(2)(d) <br />(Top) Soil Redistribution <br />The Topsoil Redistribution section modified with MR -79 in March <br />Evaluated Exhibit 2011 -6 showing the different soil zones and required soil depths for each zone and compared to Permit Map 2.05.4 -4 (Postmining Topsoil <br />2011. <br />Replacement) PR 6 MR 79 (3/2011). MAP 2.05.4 -4 INDICATES THAT LIFT A IN ZONE 4 SHOULD BE 25" AVERAGE THICKNESS - THIS DISAGREES WITH EXHIBIT <br />2011 -6 WHICH INDICATES THAT LIFT A IN ZONE 4 IS 24" AVERAGE THICKNESS. THE COMBINED THICKNESS ALSO DISAGREES (58" VS. 57 "). MAP 2.05.4 -4 <br />INDICATES THAT BENCH 1 SUBSOIL IN ZONE 8 THICKNESS SHOULD BE 10 -24" - THIS DISAGREES WITH EXHIBIT 2011 -6 WHICH INDICATES THAT BENCH 1 <br />SUBSOIL IN ZONE 8 SHOULD BE 18"+ THICKNESS. <br />26 <br />Permit section 2.05.4(2)(d) <br />Topsoil Salvage and Storage <br />Exhibit 2011 -10 gives details on locations types volumes and <br />Evaluated calculations in Exhibit 2011 -10 in comparison to calculations provided in the 2011 ARR. PLEASE INCLUDE A BULLET FOR MIXED -AREA 4 IN THE ARR <br />(Stockpiling) - Western Fuels <br />stockpile identification. An Annual Soil Balance summary was <br />REPORT SHOWING THAT THE BALANCE IS NOW ZERO. <br />Colorado will provide topsoil <br />included in the ARR, Exhibit 2011 -10, topsoil balance, shows topsoil <br />salvage depths in the Annual <br />balance calculations. <br />Report. Required to submit an <br />Annual Topsoil Balance /Spoil <br />Quality Report. <br />27 <br />Permit section 2.05.4(2)(d) <br />Cover Crop <br />ARR includes information on temporary seedings. <br />Exhibit 2011 -4 only shows long -term seeding. Temporary seedings (of cover crops) are detailed only in the ARR. Seed mixes appear to have been used <br />appropriately. Seeding rates provided in Attachment 2011 -B of ARR. No problems noted. <br />2011 ARR Review <br />Page 4 <br />