2014-04-22_REVISION - C1996083 (4)

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Susan Burgmaier -4- April 22, 2014 BOW2: The Operator believes they salvaged all topsoil that was available for salvage at the gob pile #2 area. It is noted in Appendix A that the topsoil depth available for salvage is estimated and likely different from in -field conditions. 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 2.05.4(2)(d) and 4.06.4(2)(x) and (b) and that vegetation establishment will be consistent with the post mining land use of rangeland /wildlife habitat. BRL, with the application for TR -84, proposed a revised material balance for Gob Pile #3. The material balance for all of the gob piles is intertwined, given that BRL is proposing to use excess cover material from Gob Pile #3 to cover Gob Pile #2. As such, the Division requested that BRL remove from TR -84 any proposed changes to the topsoil and subsoil handling plan, so that all material handling plans for both gob areas would be reviewed under TR -77. We have the following comments on the submittal for the Gob Pile #3 material handling plan. 8. DRMS: Pages 2 and 4 of Volume XI have been revised to change the available topsoil salvage depth from 2.4' to 1.0 -1.5', and the replacement depth from 2.4' to 1.0'. Please explain why the available salvage depths and replacement depths are being changed, and demonstrate that this change is consistent with the requirements of Rules 4.06.2(a) and 4.06.2(b). (This was Item 15 of the Division's January 16, 2014 adequacy review letter for TR -84. ) BOW2: The topsoil salvage depth should not have been changed. Please see revised pages 2 & 4 for Volume XI. Please see response in 6b for explanation of the change in replacement depth. 9. DRMS: BRL has provided a material balance sheet as new Appendix A to Volume XI. The volumes proposed for cover fill and topsoil replacement may require revision depending on the outcome of Item 15, above. (This was Item 21 of the Division's January 16, 2014 adequacy review letter for TR -84, and the reference would be to Item 8 of this document.) BOW2: The topsoil salvage depth has been revised to 2.4 feet. Please see revised Volume XI, Appendix A. Many changes have been made to Appendix A to reflect documentation gathered during the in -field survey. Please see revised Appendix A for details and material balance. 10. DRMS: Map 32 — Topsoil Distribution Plan - Please explain why the replacement depth for the F1 topsoil stockpile distribution area is being changed, and demonstrate that this change is consistent with the requirements of Rule 4.06.4(2)(a). (This was Item 41 of the Division's January 16, 2014 adequacy review letter for TR -84.) BOW2: Please see response provided in Adequacy item number 6 (b).