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40 <br />regard to the topsoil resources currently available for reclamation, the topsoil resources <br />required, and the necessary reclamation bonding calculation. <br />In scenario 41, if the mine were to resume operations early within the next permit term, <br />the next phase of stripping operations, as approved and shown in Table 24, would <br />immediately need to commence in order to allow for the required space to dispose of <br />the 800,000 -1.5 million tons of refuse generated each year from prep plant operations. <br />This continued, sequential growth of the RDA would eventually result in an excess of <br />stockpiled topsoil available for reclamation purposes, as discussed above. Additional <br />areas for storage near the RDA surface will likely need to be permitted or the topsoil <br />may be hauled to and stored in approved locations at the facility area. <br />However, in scenario #2, TC status, (the current mine status) and with no reliable <br />estimate for resumption of operations, the mine is currently at a deficit of stockpiled <br />topsoil necessary to complete the reclamation plan as currently approved and for those <br />areas presently disturbed. This deficit would persist as long as the mine remains in <br />temporary cessation. Consequently, the DRMS is requiring, for reclamation bonding <br />purposes, that a cost for importation of topsoil be included in the MT6 update to the <br />Reclamation Cost Estimate (RCE) to account for this topsoil deficit. <br />To estimate the topsoil deficit is a simple matter of subtracting the volume of topsoil <br />needed from the volume available in stockpile, as presented in the preceding <br />paragraphs ; <br />44,589 LCY(TS needed) — 30,026 LCY(available) = 14,563 LCY(import) <br />Until operations commence and conditions change at the RDA with regard to <br />additional stripping and stockpiling of topsoil, 14,705 LCY of topsoil will be required <br />for importation. Costs of importation of this topsoil are included in the RCE as a result <br />of the recalculation done for MT6. <br />The Operator will salvage stockpile and stabilize all topsoil according to the <br />performance standards in Section 4.06. Topsoil will be removed after all vegetation <br />that would interfere with salvaging operations is cleared. Topsoil will be salvaged to a <br />depth as described in the above plan and as discussed in the two paragraphs below. <br />The Operator will not be selectively handling topsoil, subsoil or parent material. <br />During the current permit term the Operator does not anticipate using selected parent <br />material as a topsoil substitute. <br />The cut area for the Bates Portal face up causes an increase in the disturbed area of <br />1.57 acres as indicated on Figure 14a. There is an estimated cut volume of 39,000 CY. <br />The estimated depth of topsoil to be removed is based on the SCS soil data included in <br />Exhibit 14 Soils Information. The soil in the area has been classified at the NE <br />Dargol-Fuera-Vamer Complex. The typical topsoil layer for this soil type is 5 inches <br />thick with a sub soil of 23 inches over siltstone. Depth to bedrock ranges from 20 to 40 <br />inches. The actual topsoil and subsoil depth will be evaluated at the time of <br />construction. Assuming 9 inches of topsoil, 1,900 BCY will be relocated to topsoil <br />Section 2.05 RN -6 10/17/2016 <br />