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r- <br />Exhibit KK, Surface Hydrology of Permit Area is confusing. A portion of the <br />14ap has a contour interva of 1 ft. and the other half an interval of 20 ft. <br />It creates a problem when trying to determine peak flows for the ditches. It <br />is required that this Map be standardized in accordance with Rules 2.10.1(1) <br />and 2.10.3(j). <br />Rule 2.05.3(5) - Topsoil Removal and Storage <br />The operator has provided a discussion regarding topsoil removal, storage and <br />redistribution. The operator committed to reapply 15 inches of topsoil based <br />on the Division's preliminary suggestion. However, based on the more detailed <br />information submitted in the response it appears that half of the proposed <br />disturbed area is the Capulin soil type which has approximately two feet of <br />usable soil available. The other half is the Ayon soil which has 8 inches of <br />usable material available. The area along the streambed contains up to 60 <br />inches of usable material. Therefore, all of the "A" and "B" horizons in the <br />Capulin soil should be salvaged, only the "A" horizon in the Ayon soil, and <br />all of the previously disturbed soil along the streambed should be salvaged <br />(up to 60 inchesl. According to the Division's calculations this will <br />provide 16-18 inches of material for reclamation of the disturbed area. <br />Therefore, the operator should commit to replacing a final thickness of 15 <br />inches. This translates into approximately 10,715 cubic yards of Ayon soil <br />and 32,260 cubic yards of Capulin soil plus the streambed soil. <br />Therefore, the 43,035 yards of soil from the Ayon and Capulin soil types will <br />cover 17.8 acres. This leaves a deficit of 5,316 cubic yards which should <br />easily be accounted for by salvaging one acre of the streambed soil to a depth <br />of 60 inches. As far as storage goes, since the operator will be stripping <br />only a few acres at a time, and then direct hauling it to backfilled areas, <br />there will only need to be one stockpile. The operation should commit to <br />placing the soil in piles where the side slopes do not exceed 2:1. He has <br />already committed to placing a ditch/berm around the toe with a sumo. <br />Rule 2.05.4(2)(d) - Topsoil Redistribution <br />As discussed in the previous section, the operator should commit to achieving <br />a final cover of 15 inches of soil which will probably require reapplying <br />approximately 18 inches before compaction. It is also recommended that the <br />operator commit to soil tests (as required by Rule 4.06.5) after <br />redistribution to determine soil suitability. The analysis should include but <br />not be limited to: pH, YAM, EC, SAR, N, P, K, Texture, and Saturation ~. This <br />commitment should be incorporated into the text of the application. <br />-2- <br />