2014-01-10_REVISION - C1996083 (3)

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Susan Burgmaier -2- January 7, 2014 substitute it is likely that topsoil was included with these samples which nullifies the analyses and justification for its use as a substitute. To justify the use of coverfill as a substitute topsoil material, BRL must take samples of coverfill directly from the coverfill stockpile at various locations and depths of the pile and run lab analyses on new samples to be used as justification for its use as a replacement/substitute for the topsoil. BOW -2: Coverfill as a substitute or replacement to topsoil will no longer be included with this revision. 5. DRMS: Given the deficiency in the available topsoil to be salvaged in the Gob Pile #2 expansion area, the depth of coverfill and topsoil replacement will need to be revised in the Reclamation section of Volume IX of the permit. Please update the topsoil replacement discussion in the reclamation plan section beginning on page 14 of Volume IX. Also, please update the material balance worksheet submitted in Appendix A of Volume IX. BOW -2: Please see revised Volume IX pages 14-15 and Appendix A. DRMS: a. During the May 30, 2013 meeting BRL indicated the proposed replacement plan may be further modified to place coverfill only on a portion of the second bench of pile #2. If this is done the soil redistribution plan will need to be revised. In regards to using coverfill material as a substitute for topsoil, Rule 4.06.2 (4)(a) indicates the Division may require that results of field -site trials or greenhouse tests be used to determine the feasibility of using overburden materials as a substitute for topsoil. If BRL decides to modify the soil redistribution plan, and only place coverfill on a portion of the second bench of gob pile #2, this area should be used as a held trial site to assure the coverfill material will be equal to or more suitable for sustaining the vegetation than the topsoil in accordance with Rule 4.06.2(4)(a). BRL will need to prepare a trial and test plan for approval by the Division; conduct vegetation sampling on this coverfill only area and compare it to an area that has been topsoiled and revegetated in accordance with the approved plan. b. Please verify the volumes of both topsoil and coverfill actually stockpiled at the site and clearly identify where this material is located. Please provide volumes for each stockpile. BOW2: An aerial survey was conducted during the summer of 2012, and the contours from that survey were used to determine the amount of coverfill and topsoil in stockpile. A figure documenting the location of coverfill and topsoil at the gob pile area has been included for review but is not intended to become part of the permit document. There are two stockpiles where the majority of coverfill material exists. One is the coverfill stockpile located east of Pond F, the other was, at the time of the aerial survey, in the bench 2/3 area. The pile that was the bench 2/3 area has been moved and is now located above bench 2, just south of the haul road. Using the 2012 contours generated from the aerial survey, a SurvCad analysis was performed. A total of nearly 101,000 CY exists in the two piles. Four feet of coverfill exists on gob pile #1, the first bench of gob pile #2 and benches 2, 3 & 4 of gob piles #2. The total for those three locations is 61,300 CY.