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<br />Also, although a portion of Phase VI and VII of Pit 2 is <br />presently overlain by Spicerton soils, which have unacceptable <br />SAR values at 12 to 18 inches below the ground level, much of <br />these two Phases are overlain by soils which exhibit acceptable <br />SAR values to at least five feet below ground level (Table 2E of <br />Appendix E of the permit application). Therefore the following <br />stipulation is proposed. <br />Before beginning mining of Pit 2 the applicant must provide <br />a plan to ensure that postmining SAR values are at least <br />comparable to premining SAR values to a depth of at least <br />the average rooting depth (five feet) below ground level. <br />Furthermore, the applicant must justify why using better <br />quality backfill material to at least the average rooting <br />depth (five feet) below ground level is either not necessary <br />or not desirable. If the applicant cannot justify why the <br />use of better quality backfill material is neither necessary <br />or desirable, than the applicant must provide an acceptable <br />plan for using more desirable material. <br />Overburden Quantity <br />During the analysis and comparison of the total overburden <br />and coal and total overburden quantities proposed to be excavated <br />as shown on Table 1-page 51, and Table 2 and Figure 2A of Adden- <br />dum II, of the permit application, several discrepancies concern- <br />ing the amounts of coal and overburden excavated and amounts of <br />overburden backfilled were found. These discrepancies are dis- <br />cussed below. <br />Table 1 on page 51 of the April, 1981 permit application <br />shows the total volume of material to be excavated from Pit 2 <br />(overburden plus coal) as 5,815,000 BCY. Subtracting the Bank <br />Cubic Yards of coal that was proposed to be excavated (converted <br />using 1.12 Tons Coal/BCY, based on information from Exhibit 2 of <br />Addendum II and coal quantities as shown on page 25 of Uolume I <br />-53- <br />