2018-10-11_REVISION - C1981044

• Permit No: C1981044
• IBM Index Class Name: Revision
• Doc Date: 10/11/2018
• Doc Name: Adequacy Review Response
• From: DRMS
• To: Peaody Energy
• Type & Sequence: RN7
• Email Name: RAR
• Media Type: D
• Archive: No

Rule: 2.04.9- Soils Resource Information
5. Exhibit 13 contains a report titled "Soils Inventory Mine Facilities, Disposal Site, and Pit 6 & 7
Areas," by Jim Walsh dated June 1, 1979. According to the report, there are two maps that depict
the soil resource study area. The Division could not locate these maps within the permit. Please
provide a copy of these maps.
10 October DRMS
Adequately addressed with maps 19 and 19A within Volume 8 of the permit.
Rule 2.04.12 Prime Farmland Investigation
6. The Williams Fork permit states that the BLM made a negative determination for the presence of
prime farmland based on soil type and precipitation. The BLM correspondence to support this
statement was not found in the permit. Please provide this correspondence.
10 October DRMS
a. The paragraph referring to the amount of annual precipitation as a determinant of prime farmland
is not supported by Rule 2.04.12 -Prime Farmland Investigation. Please remove this paragraph as
it does not support the finding of `negative determination for the presence of prime farmland.'
b. A USDA, SCS letter dated December 23, 1986 was submitted with the last response from
Peabody. The letter states that the Eagle Mine has a growing season of 77 days. This
information is inconsistent with the permit Section 2.04.8 which states the mine area has a
growing season of 120 days, and Exhibit K of the permit states the growing season is 94 days.
Please update these sections so the information is consistent.
Rule 2.03(5)- Tousoil
7. Please update the Redistribution of Soils Materials section of the permit to indicate that topsoil
replacement depths for the various disturbed areas are specified in Tables 58 to 62.
10 October DRMS
Adequately addressed
Rule 2.05.4- Reclamation Plan
The Division could not locate in the reclamation plan a description of measures to be employed to ensure that all
debris, including but not limited to acid-forming and toxic forming materials that constituting a fire hazard, are
disposed of in accordance with Rules 4.11.4 and 4.14.3 and the description of the contingency plans which have
been developed to preclude sustained combustion of such materials as required by Rule 2.05.4(2)(f).
8. Please update the reclamation plan to include these descriptions.
10 October DRMS
Adequasely addressed
Rule 2.05.6- Mitigation of Imnacts
The Fish and Wildlife Plan beginning on Page 2.05-35.2 of the permit does not fully address the items required
under Rule 2.05.6(2). A number of fish and wildlife species are identified to exist and/or occur within the permit
and affected area.
9. Please update the Fish and Wildlife Plan to discuss how future mining, reclamation and site
maintenance operations will minimize disturbances and adverse impacts to fish and wildlife species.
Please review Rule 4.18(5) to help formulate a wildlife protection plan.
10. According to the fish and wildlife plan, no rare or endangered species were observed within the
permit area during the collection of baseline wildlife resource information. However, the potential
exists for threatened and endangered species to be exist and/or occur within the permit and affected
area. Section 2.04.11 of the permit discusses the species that may exist within the permit area. The
fish and wildlife plan discusses the protection of raptors and the procedure that will be followed
should threatened and endangered species be observed at the site. However, the plan does not
Williams Fork Permit Renewal RN7 ADQ 2 Prepared by: R. Reilley, M.S. GISP
Date: October 2018