2016-12-12_PERMIT FILE - C1981019A (2)

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RULE 2 PERMITS redistribution depths. The revision also includes a requirement to annually report topsoil stockpile volumes (Volume 1, Section 2.05 "Topsoil Redistribution Plan'). This commitment to provide topsoil volumes in the annual report also applies to the Collom area. As TR -82 was approved in 2010, similar language allowing the replacement of variable topsoil depths has been included in this revision. The stockpiling of topsoil will continue until all pit development has progressed to its maximum extent. Areas available for final reclamation prior to mine closure consist primarily of backfilled pit areas. Topsoil to cover these areas will either be direct placed from areas of topsoil removal activities or topsoil will be hauled from the topsoil stockpiles. Direct placement of topsoil will be the preferred method, however, the stockpiled material will be utilized if equipment schedules, weather conditions or other operational factors make direct placement less desirable or less cost effective. After mining and regrading operations have ceased, all stockpiled topsoil will be used to reclaim the remaining pit and other disturbance areas. Topsoil will be stored in topsoil stockpiles as shown on Map 28C. Stockpiles will be constructed with outside slopes no steeper than 3H:1 V. Stockpiles are specifically located to avoid erosion from wind and water and additional compaction or contamination. As can be determined from the Topsoil Handling Map (Map 28C), all proposed stockpiles are located within stable areas. The piles will be protected from wind erosion by planting a perennial mixture as explained in Section 4.06.3 as soon as conditions allow. Proper seasons of planting will be early spring or late fall. In addition to the planted material, a considerable amount of volunteer growth can be expected to grow on all stockpiled topsoil. External erosion will be controlled through proper location of the stockpiles. No topsoil stockpiles will be placed in a drainage bottom where external erosion might pose a potential threat. Unnecessary compaction will be avoided by keeping all but essential traffic off the stockpiled areas. In accordance with Rule 4.02.7, topsoil signs will identify topsoil stockpiles. Contamination of the stockpiles will be eliminated by the careful selection of sites that are distant from the areas where actual mining activities are occurring. Drainage ways and areas near spoiling and blasting will be avoided where possible. 2.05.3 (6) Overburden Additional description of the removal, handling and storage of overburden material within the permit area is described in Section 2.05.3(1). The spoil handling monitoring plan parameters for the operation can be found below. Overburden Monitoriniz Prop -ram As discussed during the permitting of the South Taylor Mining Area (PR -02), as long as the total percentage does not exceed 15% of the total truck/shovel sequence for each drill hole, suitability should not be an issue based upon the upper overburden seam quality and the expected dilution of lower overburden materials (more likely to exhibit elevated parameter levels) through mixing as part of the logical mining sequencing of overburden and coal removal in the Collom area. In the following analysis, Colowyo demonstrates the likelihood spoil material placed near the surface of final regraded overburden areas will be unsuitable is low. This demonstration was completed by showing the total percentage of unsuitable material as it relates to the drill hole data shown in Volume 17, Exhibit 6 Item 9 for the sources of the majority of overburden to be generated in the area. A review of the analysis spreadsheet for drill hole C-04-04 shows that the source of all elevated SAR levels (> 15.0) originates from the bottom 121 feet of overburden from the bore hole. Normal overburden haulage and Collom — Rule 2, Page 79 Revision Date: 11/16/16 Revision No.: MR -166