2014-05-05_REVISION - C1996083 (2)

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Susan Burgmaier -4- May 5, 2014 New DRMS 4130114 Items: 12. BRL has proposed to supplement available cover material for Gob Pile #2 reclamation with material excavated from three proposed borrow areas. In addition to the information on the material excavation volume that BRL has provided, the Division will need the following information for the borrow areas: a. A topsoil salvage, storage, and redistribution plan, in accordance with Rules 2.05.3(5), 2.05.4(2)(4) and 4.06.4(2); b. A regrading plan in accordance with Rules 4.14.1 and 4. 14.2; c. A revegetation plan in accordance with Rule 4.15; d A sediment control plan in accordance with Rules 2.05.3.(4), 2.05.6(3), 4.05.1, and 4.05.2; e. Revised map(s) in accordance with Rule 2.10.3, clearly indicating the areas proposed for disturbance; and f. A reclamation plan and cost estimate in accordance with Rule 2.05.4. g. A commitment from BRL that materials excavated from any borrow area will be direct hauled for the purpose of covering refuse material, and will not be incorporated into the refuse material, such as for drying purposes. The Division will place a stipulation on its proposed decision for TR -77 requiring that a technical revision to address the above requirements be submitted within 45 days of issuance of the TR -77 decision. BOW2: Comment noted. 13. BRL has provided a revised coverfill material balance based on an in -field survey conducted April 09, 2014. The coverfill volume reported to be in stockpile were used to populate Appendices A for Volumes IX and XI. The stockpiled coverfill in place at the time of the survey, along with the material proposed to be borrowed from adjacent areas, is equal to the amount required to place the minimum 4' of cover (topsoil and coverfill) required by Rule 4.10.1(5). Since there does not appear to be any excess material available, it is imperative that BRL reserve the minimum stockpiled amounts at all times to ensure compliance with Rules 3.02.1 and 4.10.1(5), and pages 12 of Volume IX and 4a of Volume XI. Failure to maintain the minimum amounts would result in BRL being in violation of the Rules and approved permit. Accordingly, the Division recommends that BRL place markers in the field so that equipment operators can readily identify the minimum reserves. BOW2: Please seethe note on the bottom of Appendix A for Volume XI which states that the salvage depth could be increased above 15' to generate additional coverfill, either for the gob pile #214 area, or potentially, for uses such as mixing with gob, or reinforcing berms. BRL understand the need to keep the minimum amount of coverfill in stockpile, but also requests DRMS understand that in small quantities, coverfill will continue to be used for uses other than reclamation purposes.