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Susan Burgmaier -2- March 26, 2014 <br />#2/ #3/#4 of Gob Pile #2, the 6" of surplus material cannot be included as available <br />material for other areas of the gob pile. Please revise the material balance to <br />differentiate between material placed and material available for placement, and <br />update the balance accordingly, or clarify that BRL is proposing to relocate a <br />portion of the previously placed cover material. <br />BOW -2: Please see revised Appendix A. It is not anticipated that Bowie would remove the <br />top 6" of native material before placement of topsoil, therefore Appendix A has been revised <br />accordingly. <br />ii. BRL, in Appendix A of Volume IX, has provided an updated estimate of the <br />volume of stockpiled topsoil. The revised estimate is considerably lower than the <br />previous estimate (42,472 cy as opposed to 72,521 cy approved with TR -76). <br />Please explain why the available topsoil volume estimate has decreased, <br />and demonstrate that this change is consistent with the requirements of <br />Rules 4.06.2(a), 4.06.2(b), and 4.06.4(2)(a). <br />BOW -2: The volume approved with TR -76 was based on, a SurvCad calculated volume <br />(50,326 CY) and included estimated volumes from the borrow area, and the TR -72 & TR -76 <br />areas. The most recent volume calculated is believed to be accurate and what is actually in <br />each stockpile, not what might be available in the TR -76 expansion area. If Topsoil is <br />available, it will be salvaged, but for reclamation estimates, it was left out to be conservative <br />in our calculations. <br />As discussed in Section 2.05.3(5) the amount of topsoil that is estimated for salvage can be <br />less than the amount of topsoil actually salvaged. The reasons listed in the permit which <br />apply for the gob pile area are: <br />1. Rocky soil material made topsoil salvage very difficult. <br />2. The steep terrain made topsoil salvage very difficult. <br />3. The soil survey assumed a constant topsoil salvage depth over the entire gob pile <br />area. The topsoil depth varies, from a few inches to over a foot. <br />The Operator believes they salvaged all topsoil that was available for salvage. <br />Page 2.05 -66 acknowledges a 6" replacement depth of topsoil on the gob piles is marginal, <br />however, nutrients or other soil amendments will be applied to redistributed topsoil if <br />necessary to support plant nutrient requirements. Therefore, the Operator believes the <br />proposed topsoil replacement depth proposed is in compliance with Rules 4.06.4(2)(a) and <br />(b) and that vegetation establishment will be consistent adequate, and consistent with the <br />post mining land use of rangeland /wildlife habitat. <br />C. Item resolved. <br />6. a. BRL has provided an updated Map 32, as requested. This map was also revised <br />under TR -84, and it looks like the versioning of the maps is out of sequence. The <br />