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37 <br />As operations progress in the RDA more efficient methods may be developed to <br />handle topsoil in this area. <br />The operator plans to topsoil some areas disturbed prior to 1977. Map 15, Surface <br />Disturbance and Post mining Land Use — East Portal and Map 16, Surface <br />Disturbance and Post mining Land Use — West Portal was prepared to facilitate <br />topsoil planning. These maps show all areas where underground development waste <br />has been deposited (DR short for "disturbed refuse") and areas of limited disturbance <br />(i.e. lay -down areas, roads) where the soil profile has not been disturbed. These areas <br />are labeled DNR for "disturbed, no refuse". On July 11, 1985, soil samples were <br />taken to a depth of 18 inches. In December 1986, soil samples were taken in one - <br />foot increments to a depth of 36 inches. The results of these analyses are provided in <br />Section 2.04.9, Soils Resource Information. In general, the refuse does not exhibit <br />any apparent limiting factors, which would limit plant growth. The primary limiting <br />factor is the black color. As such, the operator believes it is prudent to concentrate <br />efforts on covering the waste with 4 to 6 inches of topsoil. The remaining areas with <br />no waste can be ripped and the seedbed prepared using standard agronomic practices. <br />There are approximately 5 acres of waste to be covered in the West Portal and 22 <br />acres in the East Portal area. Two (2) acres in the East Portal were topsoiled with 4 <br />to 6 inches during the Middle Fork diversion construction. A 1994 survey <br />documented 16, 296 LCY (13,379 BCY) of topsoil was salvaged during construction <br />of pond 004. It will require 13, 310 LCY to 21,167 LCY of topsoil to cover 25 acres <br />with 4 to 6 inches. With 16,296 LCY available from the existing stockpile, the <br />borrow requirement is 3,870 LCY. The soil will come from one of two sources: from <br />excess topsoil from the RDA salvage operations or from a borrow area east of the <br />non -coal waste dump. <br />To fulfill the topsoil borrow requirement of 3870 LCY, the operator will have a <br />balance of 3,233 BCY (3,939 LCY) of topsoil from the refuse disposal area topsoil <br />piles for final reclamation (former pile south of highway 12 and west of the RDA <br />conveyor). This material will be used if available. If not, the Division recommended <br />that the operator borrow topsoil from the lay -down area east of the non -coal waste <br />dump. This low-lying area should be a good source. No waste has been deposited in <br />this area and soil samples, to a depth of 18 inches, indicate suitable topsoil. The <br />operator will salvage the required 3,870 LCY by stripping 1.0 feet over 2.5 acres, <br />which could result in as much as 4032 BCY (4,910 LCY) of topsoil from the borrow <br />area. The lower 6 inches of soil in this area is left in place to be seeded for final <br />reclamation of the borrow area. <br />In summary, topsoil for reclamation of the waste areas located within the facilities <br />areas will be derived from the entrance road stockpile (13,379 BCY), the RDA <br />stockpile located near the RDA conveyor (3,233 BCY) or the borrow area east of the <br />non -coal waste dump (4,032 BCY) for a total of 20,694 BCY (25,205 LCY) of <br />material, which is more approximately 4,000 LCY more than what is required. <br />All of the permit text narrative presented in the twelve paragraphs above under the <br />Section 2.05 RN -6 10/17/2016 <br />