2018-04-02_PERMIT FILE - C1981019A (7)

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RULE 2 PERMITS Topsoil will normally be reapplied by hauling, in trucks, from topsoil stockpiles or from areas where topsoil has been removed for mining advance, to the regraded spoil areas and then redistributed with dozers. Alternate methods may also using a scraper to redistribute the topsoil. It is anticipated that on slopes of < 10% it will be safe to strategically place rows of topsoil in a designated pattern with haul trucks to ensure the desired four to six inches of topsoil can be dozed into position. If a dozer operator does not do this properly, they will not have enough material to cover the entire area and it will be obvious what has occurred. Depth control on the Sagebrush Steppe areas will be verified as the project progresses and any deviations from the plan will be rectified at that time. Depth readings will also be taken after the area has been completely topsoiled, sufficient to ensure that Colowyo can demonstrate compliance with the plan. Even if scrapers are used to initially lay topsoil down, it is anticipated that some dozer work will be needed to do the finish work. The required volume of material will be at/on the location. Verification work will lead to additional dozer/scraper work if necessary to ensure proper final placement. If depth control becomes an issue, staking will be initiated as an additional guide for operators. On areas of > 10% slope it is anticipated that dozers will work together with scrapers to accomplish a gradually thicker application of topsoil on these slopes. As Colowyo has always done, depth stakes at regular intervals will provide guidance to the operators. Depth readings will be taken while the operations are progressing and any issues will be rectified at that time. Depth readings will also be taken after the area has been completely topsoiled, sufficient to ensure that Colowyo can demonstrate compliance with the plan. The allocated volume of topsoil for each area will be hauled to the location, most likely with haul trucks and scrapers as close as safely possible to the final intended location, then dozed into place or placed via scrapers. Verification work will lead to additional dozer/scraper work if necessary to ensure proper final placement. Colowyo will institute a topsoil depth verification program to document ecologically significant variations in topsoil where applicable (i.e. grassland areas) and confirm more uniform topsoil reapplications (i.e. sagebrush steppe areas). It will consist of recording topsoil depths on five acre centers overlaid on each reclamation unit, similar to re -graded overburden suitability monitoring. Specific depth sampling point locations and results will be recorded and reported in the subsequent years Annual Reclamation Report within the Topsoil Volume Inventory section. The topsoil depth verification program is not intended nor should it be used as a topsoil volume verification method as the volume of topsoil will be planned, monitored and verified through load counts and engineering plan designation of placement of the material on a reclamation unit basis. Overall topsoil balance oversight is performed and reported annually in the Annual Reclamation Report. The overall goal of both the Division and Colowyo is to replace the entire resource in a manner that promotes the likelihood reclaimed areas will meet the success criteria for Phase III Bond Release after the required liability periods and thereby create reclaimed lands that reflect the desired post -mine land use (grassland and sagebrush steppe). Reapplied topsoil will be left in a rough condition to help control wind and water erosion prior to seeding. In the case of scraper -applied topsoil, dozers usually cross -rip along slope contours at intervals of about 50-75 feet to provide additional surface roughness. Also, contour furrows are almost always put in place when scrapers are utilized to minimize any sheet flow from the topsoil surface. Due to the specific equipment used for the Sagebrush Steppe areas, topsoil will be left in a more smooth condition to ensure proper seeding depth as described in the text. Any topsoil put into final position with a dozer will by practice be in a state of rough condition. Previous roughening efforts at Colowyo have been extreme, leading to difficulties in placing seed at biologically viable depths. The addition of more contour furrows will reduce sheet flow and moderating the roughness will allow a greater percentage of seed to germinate and provide ground cover that will also alleviate rilling and sediment control issues. As Coloywo transitions into areas of steeper slopes, density of cross ripping will be tightened to increase surface Collom — Rule 2, Page 87 Revision Date: 11/16/16 Revision No.: MR -166