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Page 3 Mitch Simmons November 2, 1979 procedures must be consistent with and integrated into the mine plan. U.K The mine plan maps seem to indicate that a topsoil stockpile will occupy px the present location of one of these existing dumps. This is unacceptable. The presence of acid materials in the existing mine waste dumps raises additional questions regarding the chemical nature of the overburden on the Bourg property. In order to identify these acid and toxic materials, as required by the federal interim regulations (715.178), the applicant must complete an overburden sampling program, according to the following specifications: 1. The procedures for_ sampling and analysis specifed in the Alontana guidelines should be followed. 2. Two holes, as described on page 6R of the revised application, should provide adequate sampling. However, the applicant must provide a map shocaing the location of these holes prior to permit approval. 3. In addition to the parameters listed iii the Montana guidelines,.the following analyses must be performed foi the lithologic units icmnediately adjacent to the coal, the coal itself, and the partings in the coal: whole rock sulfate; pyrite; marcasite. The requested overburden analysis data, plus a narrative interpretation of these data, must be submitted to this office for review prior to any actual mining, but no later than August 1, 1980. Ii, in the opinion of this Division, acid or toxic forming strata are present, I~'latiron Paving Co. is required to submit a revised mining and reclamation plan which describes special handling of these strata, in order to insure that they are disposed of in such a manner as to prevent any adverse affects on reclamation of the site. All applicable requirements of state and federal lacy must be met. IV. Topsoil Salvage and Replacement At this time, the Bourg application does not contain an acceptable topsoil salvage plan. The sail sampling and analysis which was performed by John Havlin from CSU is adequate for the mine site. However, no inter- pretation of the raw data was provided, nor were the results of. his study incorporated into the mine plan. In the absence of an acceptable topsoil salvage program, the staff has taken the time to analyze and interpret L-}ce raw data provided by John Havlin. As a result of this analysis, a map of sufgested topsoil salvage depths has been prepared for the Bourg property. 1 would be happy to discuss these staff suggestions with you. (cont`d)