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4. As noted in response number l above, the 19.5 acre light-use road leading down to Pond 004 should be labeled on the map with the acreage and associated topsoil depth. Please revise the map and permit text accordingly. 5. See response to number 3 above. 6. This response is adequate. Seneca states that the subsoil material will be hauled from an existing stockpile area located in the spoils and the final highwall reduction area at the top end of the Wolf Creek Pit. These overburden piles should be located on the map with the corresponding volume. The Division views the subsoil material as a supplement to topsoil if the topsoil replacement depth is less than 6 inches. If the topsoil to be placed over the subsoil is less than 6 inches, then the subsoil material should be tested in accordance with Rule 4.06.2(4)(a). 1f the topsoil replacement depth is greater than 6 inches, then the subsoil is not considered as a supplement and does not need to be tested. The topsoil replacement depths for areas 004, 005 and 006 were revised from the original submittal. The Division believes that additional topsoil material can be accounted for where there aze proposed rock drainage ditches, stocktanks and additionaUproposed roads. The topsoil located in the Tie-Across-Haul-Road piles could also add to the replacement depth at the Seneca II Mine. Adding all of the topsoil sources above, the Division estimates neazly 100 acre-feet of additional topsoil is potentially available. The supplementary material could potentially add an additional 3 inches of topsoil over the pit areas (409 acres) delineated in zones 002, 004, 005, 006 and 007. The average topsoil depth for all five zones is roughly 8 inches. An additional 3 inches would increase the overall depth to 11 inches over 409 acres. It seems more logical to average all five zones into one uniform replacement depth of 11 inches, rather than have them vary from 2-3 inches in five separate zones. In light of the topsoil deficit at the mine, Seneca should take all of these factors into account in the topsoil management plan. Please reevaluate the material balance to account for the potential sources noted above. The permit pages should be revised to account for this additional material and the map should be updated accordingly. 9. This response is adequate. 10. This response is adequate. 11. Seneca states that the shops, boneyazds and offices aze the only areas which may utilize a topsoil substitute. This is one of the last areas to be reclaimed at the mine, so sampling of the subsoil material may occur prior to reclamation. Seneca should add a commitment to the permit to sample the material, or as an alternative, the Division will add a stipulation