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<br />50 <br /> <br />draw and a subsidence control plan will be implemented for mitigating <br />possible impacts from mining-induced seismicity. (Possible subsidence <br />impacts to the dam and reservoir and mitigation measures are described <br />in the following discussion of the subsidence control plan.). <br /> <br />MCC’s surface water monitoring plan is described in Exhibit 71 for the <br />South of Divide and Dry Fork lease areas, in Exhibit 71a for the Sunset <br />Trails area, and in Section 2.04 of the permit application for other areas. <br />As of late 2008, MCC monitors surface water quantity and quality at 22 <br />stream stations, comprised of 10 stations with continuous recording and <br />12 stations with instantaneous recording. A minimum of one year of <br />monthly baseline data has been collected on all streams prior to mining in <br />a watershed <br /> <br />3. Summary and Findings <br /> <br />The Division has reviewed the Probable Hydrologic Consequences due to <br />mining operations for the groundwater and surface water systems at the West <br />Elk Mine. The Division finds that underground mining at the West Elk Mine <br />will not cause material damage outside the permit area and hydrologic impacts <br />will be minimized within the permit area. (2.07.6(2)(c)). <br /> <br />IV. Topsoil <br /> <br />Baseline soils information can be found in Section 2.04.9 in Volume 1 of the PAP. A <br />suitability analysis of the topsoil was performed before the site was disturbed. In most <br />areas topsoil quality as seedbed material is considered moderate to good, with a few <br />areas that are considered poor. Soil mapping and physical descriptions of the soil are <br />based on SCS soil surveys completed for the area. <br /> <br />The operator's topsoil salvage and redistribution plan can be found in Section 2.05.4. <br />Topsoil and subsoil stockpiles are shown on Map 53. <br /> <br />Topsoil will be removed ahead of surface disturbance activities. Any vegetative cover <br />that would interfere with topsoil removal will be removed first. The West Elk Mine had <br />already completed the majority of topsoil and vegetation removal when the mine <br />facilities were constructed in 1981. Since the majority of reclamation will occur upon <br />completion of mining, topsoil stockpiles have been designed and maintained so as to <br />minimize wind and water erosion and to preserve the seedbed material. Stockpiles in <br />place for five years or more have been or will be seeded with the permanent seed mix. <br /> <br />Subsoil not fully suitable for seedbed material is also excavated, as necessary, for <br />construction purposes. Topsoil consisting of all of the A horizon and part of the B <br />horizon of each soil series present is stripped before construction begins. <br /> <br />The operator will distribute 12 to 18 inches of topsoil over the entire disturbed area. <br />However, the Lower Refuse Disposal Area will be replaced with 18 to 24 inches of <br />topsoil and subsoil. A variance to the four feet of nontoxic cover has been granted to