2014-04-30_REVISION - C1996083 (2)

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William A. Bear Page 3 of 8 April 30, 2014 believes the proposed replacement depth proposed is in compliance with Rules 4.06.4(2)(a) and (b) and that vegetation establishment will be adequate, and consistent with the post mining land use of rangeland /wildlife habitat. DRMS 4130114: BRL's adequacy review response letter provides an explanation for the significant difference in the topsoil material that was projected to be salvaged in the Gob Piles #2 and #4 disturbed areas. The revised pages 14 and 15 of Volume IX as well as revised Appendix A do not provide an explanation of why less topsoil is available for reclamation than was projected. Please revise pages 14 and 15 and Appendix A of Volume IX to include an explanation for the discrepancy in the predicted and actual topsoil salvage volumes, as outlined in BRL's adequacy response letter. The revised plan allows for the growth media to be replaced in a uniform, stable thickness. The thickness of material appears to be the maximum amount available given the circumstances discussed in BRL's response letter. With the original submittal of TR77, BRL submitted soil analysis results of six samples of cover material placed on the first bench of gob pile #2. BRL had originally intended to use cover material as a substitute /replacement for topsoil in certain areas, and the sample data was intended to support that request. BRL has since abandoned this plan and removed that proposal from the revision application materials. However, the soil analysis results remain applicable to the current proposal. The material sampled was reported to be cover material. During the May 30, 2013 meeting between the Division and the Operator; it was found that topsoil may actually have been placed over the cover material on this bench and that the labeling of the sample material as solely cover material may not be accurate. In either case, the material sampled should have been either all cover material or a mixture of cover material and topsoil. The Division reviewed the lab results of the samples under the lens of its suitability as a growth media, and found that the growth media was comparable in terms of suitability to the topsoil originally projected to exist in the gob pile #214 area. Given the lack of topsoil available for salvage according to BRL, the growth media available at the revised depths is the best material available for reclamation, establishing the proposed vegetation and achieving the post mine land use of rangeland and wildlife habitat, and thus complying with Rule 4.06.4(2)(c).