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Susan Burgmaier -4- March 26, 2014 <br />Rules 2.05.4(2)(d) and 4.06.4(2)(a) and (b) and that vegetation establishment will be <br />consistent with the post mining land use of rangeland /wildlife habitat. <br />BRL, with the application for TR -84, proposed a revised material balance for Gob Pile #3. <br />The material balance for all of the gob piles is intertwined, given that BRL is proposing to <br />use excess cover material from Gob Pile #3 to cover Gob Pile #2. As such, the Division <br />requested that BRL remove from TR -84 any proposed changes to the topsoil and subsoil <br />handling plan, so that all material handling plans for both gob areas would be reviewed <br />under TR -77. We have the following comments on the submittal for the Gob Pile #3 <br />material handling plan. <br />8. DRMS: Pages 2 and 4 of Volume XI have been revised to change the available topsoil <br />salvage depth from 2.4' to 1.0 -1.5', and the replacement depth from 2.4' to 1.0'. <br />Please explain why the available salvage depths and replacement depths are <br />being changed, and demonstrate that this change is consistent with the <br />requirements of Rules 4.06.2(a) and 4.06.2(b). (This was Item 15 of the Division's <br />January 16, 2014 adequacy review letter for TR -84.) <br />BOW2: The topsoil salvage depth should not have been changed. Please see revised <br />pages 2 & 4 for Volume XI. Please see response in 6b for explanation of the change <br />in replacement depth. <br />9. DRMS: BRL has provided a material balance sheet as new Appendix A to Volume XI. <br />The volumes proposed for cover fill and topsoil replacement may require revision <br />depending on the outcome of Item 15, above. (This was Item 21 of the Division's <br />January 16, 2014 adequacy review letter for TR -84, and the reference would be to Item <br />8 of this document.) <br />BOW2: The topsoil salvage depth has been revised to 2.4 feet. Please see revised <br />Volume XI, Appendix A. In addition, the coverfill pile (West, in gob footprint, 2.6 Ac.) <br />has been revised. Originally, a 3' salvage depth was used, however, salvaging efforts in <br />the eastern area were between 10 -20'. Therefore, the number was updated using a 10' <br />salvage depth. This revision changes the total amount of coverfill & topsoil available <br />from 233,357 CY to 292,5354 CY. <br />10. DRMS: Map 32 —Topsoil Distribution Plan -Please explain why the replacement <br />depth for the F1 topsoil stockpile distribution area is being changed, and <br />demonstrate that this change is consistent with the requirements of Rule <br />4.06.4(2)(a). (This was Item 41 of the Division's January 16, 2014 adequacy review <br />letter for TR -84.) <br />BOW2: Please see response provided in Adequacy item number 6 (b). <br />11. DRMS: Once the material balance has been finalized, prior to approval of TR -77, <br />the reclamation cost estimate will likely need to be updated to reflect the final material <br />