2014-04-22_REVISION - C1996083 (4)

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Susan Burgmaier -2- April 22, 2014 available for reclamation of the gob piles. Included in that figure is the material that has been placed on Gob Pile #1, and Benches #1 and #2/ #3/ #4 of Gob Pile #2. The material placed on those areas was placed at a depth of 4'. The revised proposal is to place 3.5' of cover on all of the gob areas. BRL presents a calculation to demonstrate that a total of 263,135 cy of cover material will be required to cover the gob piles at a depth of 3.5'. Unless BRL is proposing to remove and relocate the upper 6" of material on Gob Pile #1 and Benches #1 and #2/ #3/ #4 of Gob Pile #2, the 6" of surplus material cannot be included as available material for other areas of the gob pile. Please revise the material balance to differentiate between material placed and material available for placement, and update the balance accordingly, or clarify that BRL is proposing to relocate a portion of the previously placed cover material. BOW -2: Please see revised Appendix A. It is not anticipated that Bowie would remove the top 6" of native material before placement of topsoil, therefore Appendix A has been revised accordingly. ii. BRL, in Appendix A of Volume IX, has provided an updated estimate of the volume of stockpiled topsoil. The revised estimate is considerably lower than the previous estimate (42,472 cy as opposed to 72,521 cy approved with TR -76). Please explain why the available topsoil volume estimate has decreased, and demonstrate that this change is consistent with the requirements of Rules 4.06.2(a), 4.06.2(b), and 4.06.4(2)(a). BOW -2: The volume approved with TR -76 was based on, a SurvCad calculated volume (50,326 CY) and included estimated volumes from the borrow area, and the TR -72 & TR -76 areas. The most recent volume calculated is believed to be accurate and what is actually in each stockpile, not what might be available in the TR -76 expansion area. If Topsoil is available, it will be salvaged, but for reclamation estimates, it was left out to be conservative in our calculations. As discussed in Section 2.05.3(5) the amount of topsoil that is estimated for salvage can be less than the amount of topsoil actually salvaged. The reasons listed in the permit which apply for the gob pile area are: 1. Rocky soil material made topsoil salvage very difficult. 2. The steep terrain made topsoil salvage very difficult. 3. The soil survey assumed a constant topsoil salvage depth over the entire gob pile area. The topsoil depth varies, from a few inches to over a foot. The Operator believes they salvaged all topsoil that was available for salvage. Page 2.05 -66 acknowledges a 6" replacement depth of topsoil on the gob piles is marginal, however, nutrients or other soil amendments will be applied to redistributed topsoil if necessary to support plant nutrient requirements. Therefore, the Operator believes the proposed topsoil replacement depth proposed is in compliance with Rules 4.06.4(2)(x) and