2014-01-22_PERMIT FILE - M2013064 (10)

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The OMLR history is replete with the approval and release of similarly sited and equally committed operations whose salvage of the upper six inches of the solum was sufficient, even in the face of soil profile descriptions where a formed and deeper A or B profile is evident. The C profile has never been considered to our knowledge. There is neither an A (except for the Ap layer created by cultivation) for the Unit 3 soils. There is a 0 -4 inch A layer for the Unit 10 soils, underlain by a C profile, and lacking a B soil profile horizon. In this instance, a 0 -48 inch description for Unit 3 Soils simply means soil may be absent or poorly developed to a depth of 48 inches. The variation is too great to even map, and soil is often absent as evidenced by exposed sand and gravel at the surface within this area. The lower depths of this soil unit are commonly sand and gravel, which is a recoverable resource, as is the excess soils where it exists, commonly utilized off -site for urban and infrastructure development, for which the economy of this state relies. There is no evidence that increased soil depths will benefit the final reclamation and stability of the location. Since the majority of the area where soils are impacted are within the extraction limits, the operator is more than willing to keep soils in -situ outside of the extraction limits to minimize disruption of the soil structure, texture, percent organic matter and other soil qualities destroyed during salvage and stockpiling. This reduces the total soil salvage volume to 3,648.29 cu.yds., or a decrease from the 5,307.87± cu.yds. indicated under Exhibit L - Reclamation Costs, of 1659.58 cu.yds. Regardless, adequate area for salvage and placement of soil is maintained within the existing stockpile area shown under Exhibit C -2; Extraction Plan Map. 6.4.7 Exhibit G - Water Information 13.The Division's engineering staff reviewed Exhibit G - Water Information. A copy of the review memo from Tim Cazier, P.E. is attached. Acknowledged. Refer to correspondence of 13 January 2014 from AWES, LLC; and correspondence of 14 January 2014 from Flow Technologies. Associated attachments and revised maps are included with this correspondence. 14.Groundwater monitoring well are mentioned in the Dewatering Evaluation Report by AWES, LLC and were observed during the pre- operation Varra Companies, Inc. Coulson Resource Project OMLR M- 2013 -064 9 Correspondence to Peter Hays 21 January 2014