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CommentlResponses, TR-62 <br />Page 5 <br />additional lands are reclaimed. Upon approval of TR-62, all future reclamation units will <br />have topsoil replaced at an average depth of 8.0 inches as specified under Section 2.05 <br />under °Topsoil Redistribution Plan" (page 2.05-41. <br />8. In the revised text of amended Section 4.06.4, there is a statement indicating, "historical <br />replacement depths for reclaimed azea units aze tracked in the Annual Report". It is not <br />clear whether this refers to tracking of applicable replacement depth requirements, or <br />actual monitoring based replacement depths. Also, we could not find any replacement <br />depth data for reclaimed area units in the most recent Annual Reclamation Report. <br />Please provide further explanation regarding soil replacement depth tracking, <br />amend the teat for clarification, and provide the referenced tracking data for <br />inclusion in the 2004 Annual Report, if it was erroneously omitted. <br />Response: This is probably an old statement that was once true, but we can find no <br />evidence of this data in current annual reports. However, with our agreement to provide <br />such data in future annual reports (See response to Items 4 and 11), the statement <br />again becomes true. No text changes have been made. <br />9. In reviewing the 2004 Annual Reclamation Report sections relevant to the issue of <br />topsoil replacement thickness, I noticed a nanrative interpretation of a remedial measure <br />that is incorrect, and needs to be amended. In Section 8-Regraded Overburden <br />Sampling, under Rule Requirement, there is narrative indicating that there originally was <br />a requirement that "suspect" overburden materials were to be covered with at least five <br />feet of acceptable material, but that subsequently this requirement "was reduced to 18 <br />inches of topsoil cover". A Colowyo letter of January 4, 1983 and a Division letter of <br />January 24, 1983 were referenced for the original and subsequent requirement, <br />respectively. <br />The minor revision sampling plan was approved by the Division as submitted in the <br />January 4, 1983 Colowyo letter. The requirements were not modified by the Division's <br />January 24, 1983 approval letter. Apparently, the following sentence from the Division's <br />letter resulted in some confusion. <br />It should be recognized that the suspect levels, which would trigger further analysis <br />and/or selective handling, aze based on the fact that 18" ofnon-saline, non-sodic topsoil <br />will be replaced over regraded spoils. <br />This statement merely noted that the overburden suspect levels reflected the fact that the <br />normal reclamation practice as set forth in the approved reclamation plan would include <br />covering graded spoils with 18 inches of good quality topsoil. It did not alter any of the <br />remediation requirements addressed in the plan submitted by Colowyo. <br />The referenced page from the 2004 Annual Reclamation Report should be amended <br />as appropriate, to eliminate reference to modification of the remedial requirement <br />to cover suspect overburden material greater than one acre in extent with at least 5 <br />feet of suitable material. <br />