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.. <br />41 ' • • <br />as we approached the southern third of the property the surface <br />texture and soil color changed rather dramatically. <br />Coincidentally, this is the area where they were having the erosion <br />problems. We talked for a few minutes about what could be done for <br />the rills and gullies forming and then walked down to the sediment <br />pond and up to where the topsoil stockpile was located. As you may <br />recall at that time I questioned you about the topsoil stockpile <br />and if all of the material had been reapplied as required because <br />there seemed to be quite a pile of soil remaining. It also became <br />rather obvious from that vantage point that topsoil had NOT been <br />replaced on the southern end of the regraded area. This was due to <br />the fact that the topsoil stockpile and the northern regraded area <br />were the same color but the southern end was a completely different <br />color. This was the same area that displayed a different texture <br />and increased erosion. <br />Now maybe this is coincidence but I don't think so. The stockpile <br />remnant that we were standing on also appeared to contain a <br />significant amount of material as evidenced by the length, width <br />and extension above the natural slope. A11 of these items taken <br />together, the excessive erosion, the color and texture change, the <br />color of the topsoil stockpile and where is was obvious that <br />topsoil had been applied, the extra material, all lead me to <br />believe that not all of the topsoil was even replaced to begin <br />with. <br />The Division should not issue a variance on reducing the topsoil <br />replacement depth if all available topsoil has not been replaced <br />and I think this may be the case at Rimrock. The operator has also <br />not explained why there is a shortfall of topsoil to begin with. <br />A reasonable explanation of how the mining proceeded and where <br />topsoil was stripped and so on should be provided to the Division <br />to help justify our decision to reduce the reapplication depth. I <br />am not sure how much topsoil is left in the pile but even 800 cubic <br />yards would cover an acre to a depth of 6 inches which is better <br />that what is currently out there on the southern end. If there is <br />not enough topsoil to cover the remaining untopsoiled area we may <br />have to reevaluate the situation at that time. <br />I would propose that the operator demonstrate that all topsoil that <br />was removed was replaced, explain why there is a shortage of <br />topsoil to begin with ( and I don't mean SCS letters saying there <br />is only 4-6 inches available; We determined through baseline that <br />they would be able to replace 15 inches), submit their own field <br />data showing that there is 11 inches of topsoil available (my <br />understanding is that the only reason they are going with 11 inches <br />is that the Division dug some holes and deduced that they had <br />reapplied 11 inches). Once this is done and it is clear that all <br />available topsoil was stripped and reapplied the variance could be <br />granted. <br />The bottom line is that 11 inches of topsoil should be enough to <br />meet their reclamation objectives but a variance should not be <br />granted if all available material has not been used. If you are <br />