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suitable for this purpose. Please consider these recommendations, and amend relevant narrative and Table 141 notes as appropriate. 10c. Amended Table 14-1 and text on amended page 14-8 indicate that non-toxic cover soil for the top of the RSRDA will be obtained from excess material in the vicinity of the lower parking area. Note that sample data referenced on amended page 9-4 suggests that pockets of unsuitable soil may be intermingled with suitable materials in this area, and narrative states that "the variability in salinity at this site will require additional sampling during the borrowing operations." Soil samples from the lower parking area are designated 96-1 through 98-3, and 97-1 through 97-3. The upper zone of the 96-2 profile would exceed the "topsoil threshold° for SAR, and the lower zone would exceed the "subsoil threshold" for SAR. The upper zone of 96-3 would exceed the topsoil SAR threshold. The entire 97-1 profile is unsuitable for topsoil or subsoil, due to high EC levels and extreme SAR levels. Please provide amended narrative within the appropriate section of Tab 14 describing the procedure for additional sampling and segregation, along with a commitment that materials placed as subsoil and topdressing will be In conformance with specified permit criteria for refuse area subsoil and topsoil. Please evaluate alternative sources of soil to be utilized should sufficient soil of suitable quality be unavailable in the lower parking area, or should segregation of suitable from unsuitable materials as necessary to meet specified criteria prove to be not practicable, due to the extent of intermingling. 11. In association with the permit renewal adequacy review, DMG prepared an updated cost estimate, which indicated that additional bond in the amount of $54,984.00 would need to be submitted. The operator's response was that a Phase 1 Bond Release Application would be submitted, and that additional bond should therefore not be required. The bond release application was subsequently submitted, although certain additional documentation is necessary in order for the application to be deemed administratively complete. The Division finds the operator's request to be reasonable, in view of the extensive reclamation work that was Implemented during 2002. A revised cost estimate will be completed in conjunction with the Division's Phase 1 bond release proposed decision, and request for additional bond submittal will be suspended pending the bond release decision. 12a. The proposed final contours for CBA-2 as depicted on Exhibits 9C and 60 appear to comply with applicable requirements. Two SEDCAD demonstrations, one fora 2% slope and ane fora 5% slope were submitted for the Coal Gulch (Re-Channelized Section). No problems were noted with either SEDCAD run. However, it is unclear to which portions of the Coal Gulch the SEDCAD runs pertain. For example, one portion of the Coal Gulch (Re-Channelized Section) has a slope of up to 8% as depicted on Exhibit 9C. Please label Exhlblt 9C to indicate the channel segments that pertain to the SEDCAD demonstrations. To ensure adequate riprap sizing, a SEDCAD run should be submitted for the steepest portion of the Coal Gulch (Re-Channelized Section). Amended cross-section D-D', on amended Exhibit 53 depicts "original ground" end °final ground", and references Exhibit 52 for cross-section location. Exhibit 52 (Certification Date 1-10-97) depicts final contours that no longer correspond to the final contours as depicted in the cross-section or on Exhibits 9C and 60. The out-dated final contours on Exhlblt S2 should be amended to corcesponded to the referenced cross-section and exhibits. The Overburden Storage Area No.12a, which is no longer proposed, should be removed from the amended Exhibit 52. 12b. Response adequately addressed wrresponding RN-4 PAR concern.