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Minor Revision No. 128 <br />September 21, 1994 <br />Page 3 <br />inaccurate, then a more detailed soil survey may be required. <br />The method used by MCC to verify topsoil salvage is acceptable <br />and is a fairly common practice. However, MCC should also <br />verify topsoil depths against their baseline information. <br />The Division's original question originates from the <br />possibility that there is a topsoil deficit, which has been <br />addressed elsewhere in this letter. Once that has been <br />determined, this question may not be as critical and the <br />Division can verify topsoil stripping depths in the field. <br />The Division used a uniform average of 15 inches, also used by <br />Envirocon, to determine topsoil depths. MCC has committed to <br />placing a minimum of 12 inches of topsoil. Typically, a few <br />more inches is applied to account for compaction while the <br />topsoil is being placed. Therefore, the use of 15 inches is <br />appropriate. <br />Revised page 2.05-44, in the context of the method to be <br />utilized to verify soil stripping, is acceptable; however, a <br />comparison should be made between actual topsoil stripping <br />operations and predictions made in the baseline. This <br />comparison could be made in the annual reclamation report. <br />4. Map 40, Soils Map from VTN Photo Mosaic, does cover all areas <br />disturbed by the West Elk Mine. Map 41, SCS Soil Survey Map, <br />did not, and the Division requested that this map be updated <br />to include all disturbed areas. MCC updated Map 41 as <br />requested and is acceptable. Replacement of Map 40 is not <br />required at this time, as indicated in MCC's responses. <br />5. The Division believes there are enough discrepancies between <br />Map 56 and 57 and the Envirocon map, to continue to pursue <br />this issue. The Division asked MCC to provide an explanation <br />to clarify which map is correct, when boundaries deviated. <br />This information was not provided. The Division has compared <br />Map 56, Topsoil Removal Plan, with the Envirocon map and found <br />that the following areas where topsoil was removed according <br />to Map 56 will not be topsoiled per the Envirocon map: <br />^ Upper Diversion Ditch (DCW-lA and DCW-1B) <br />^ Ditch D1-6 <br />^ Several areas between FW-1 and MB-1 (storage area) <br />^ South of FW-1 <br />^ Embankment below shop, fuel storage, 3-sided warehouse <br />^ Area near water intake building <br />^ Embankment below lower mine access road <br />^ Area around stacktube and reclaim system pad <br />