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Page 4 stitch Simmons Yovember 2, 1979 In addition [o a map of topsoil salvage depl-hs, the operator is required to explain in detail the proposed sequence of topsoil salvage operations, as well as topsoil stockpiling and replacementrin relation to the mine plan. A description of topsoil salvage from the haul roads, office, sedimentation ponds, dumps, and weathered coal stockpile is also required. A number of contradictory and unacceptable statements regarding topsoil salvage appear in the application. These follocr: 1. On Page 12R, the applicant states that soil will be salvaged only in the draws, and that no soil will be salvaged from the Knolls and ridges. This is unacceptable. Baseline soils information provided by the applicant indicate that suitable topsoil is present on the knolls and ridges. 2. The quantity of topsoil to be salvaged is specified as 144,000 BCY at some points in the application (Table 3A, pp. SR and 9) and as 210,000 BCY at others (p g. 12R). This discrepancy must be resolved. The specified topsoil volume must be based on topsoil salvage depths. (\3.1 This office cannot approve the replacement of four feet of topsoil tel./ above the compacted clay membrane adjacent to Piann Draw. Amore ,eft, uniform distribution of available topsoil on the reclaimed surface would better achieve the goals of revegetation. Please adjust the proposed topsoil replacement depths to reflect this change. 4~. If the applicant still crishes to attempt to create a wet meadoca adjacent to Hfann Draw through the use of a clay membrane, the staff would suggest burying this membrane to a greater depth (perhaps 8 feet?) with overburden material. Topsoil should then be replaced on the overburden. 5. The information in Table 3A indicates that topsoil mill be salvage.cl only during the first three years of mining. If this table is correct, this would indicate that topsoil will not be salvaged in the East Dump area. Please correct this apparent error in a detailed, comprehensive topsoil salvage program. 6. The statement appears on page 12R that saline and sodic soils on the proposed site of the Horseshoe Dump will not be salvaged. This is unacceptable. At least 6" of this c~at.crial must be salvaged, but it should be stockpiled and replaced separately from the other soils. The s[aff crould be glad to discuss this in greater detail with you. (cont'd)