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39 <br />topsoil harvested from the footprint of the previously reclaimed SW coal stockpile <br />(4,000 BCY) and the rock dust bin area topsoil (1,140 BCY). <br />The topsoil borrow area has been used sparingly since its original permitting and <br />likely holds about 3,000 BCY of topsoil material of the 4,032 BCY originally <br />estimated for this approved borrow area. <br />The 2005 Annual Reclamation Report review focused specifically on rectifying acres <br />to be reclaimed and topsoil volumes available to ensure that adequate topsoil <br />resources were present. From 2005 until 2010, very limited topsoiling and reseeding <br />took place, the exception being the completion of topsoiling at the DWP (-2,000 <br />BCY). Since 2005, very few additional acres have been disturbed, the most <br />significant being the Bates Portal (+1,900 BCY) and the rock dust tank area (+1,140 <br />BCY). Using the 2005 numbers as a starting point, the following paragraphs provide <br />additional text narrative regarding topsoil needs and available topsoil resources as <br />they exist in 2014. <br />From review of Figure 6, Table 24, and cross-section A -A', NECC believes that the <br />worst-case disturbance is realized when the RDA is constructed to the level of the <br />fourth or fifth bench elevation, which is the constructed condition in 2014. The <br />exposed, un -reclaimed operational surface in 2014 is 19 acres, as verified by the <br />Division. To be conservative and to account for any variation of this maximum RDA <br />exposure, NECC assumes for reclamation bonding calculation purposes that the <br />worst-case exposure at the RDA would be 23 acres, an increase of about 20% over <br />the actual 2014 condition. This worst-case exposure will persist until the RDA is <br />fully constructed and final reclamation is completed in the year 2021. Therefore, the <br />acres requiring topsoil (and which are disturbed as of January 2014): <br />Area acres requiring topsoil <br />East Portal 19.31 <br />West portal 5.63 <br />RDA 23.0 <br />Comments <br />includes Bates and rock dust areas <br />worst-case exposure <br />Given the above acreage estimates the following topsoil resources are required: <br />Area topsoil needed (LCY) Comments <br />East Portal 12,981 5 inches (includes Bates and rock dust areas) <br />West portal 3,784 5 inches <br />RDA 27,824 worst-case, 9 inches required <br />Total 44,589 <br />The two most likely scenarios over the next permit term (2014-2019) are resumption of <br />coal mining and processing operations (operational status) or continuation of the <br />current temporary cessation status (TC status). Each presents a different outlook with <br />Section 2.05 RN -6 10/17/2016 <br />