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Technical Revision No. 67 - PAR 1 <br />February 17, 1994 <br />Page 3 <br />4. The area of proposed disturbance is within the Absarokee Work <br />Loam Soil Classification Zone. MCC's permit indicates (Table <br />30) that topsoil salvage depths for Absarokee soil average 20 <br />inches. The Division calculates that 17.4 acres of <br />disturbance with 20 inch depth of salvaged topsoil should <br />yield 46,880 yds3. Please explain the discrepancy between the <br />35,000 yds3 that is proposed to be salvaged, and the amount <br />that should be salvaged. <br />5. Soil descriptions for this type of soil specify that Absarokee <br />Soils are "subject to packing and irreversible puddling if <br />handled wet". The Soil Conservation Service recommends that <br />topsoil should not be handled when moisture content is greater <br />than 75 percent of field capacity. When does MCC propose to <br />strip topsoil for this area? Pursuant to 4.06.2(5), the <br />Division strongly recommends that no topsoil be disturbed <br />until soil moisture conditions are conducive to disturbance <br />with minimal compaction and soil structure degradation. <br />6. The best revegetation results are characteristically found on <br />soils that are placed and seeded directly after being <br />salvaged. Better soil structure due to one-time handling and <br />increased soil microbial activity are two of the major <br />contributors to this fact. The Division suggests that MCC <br />coordinate topsoil stripping operations with reclamation on <br />the western side of the refuse pile so that topsoil can be <br />live hauled. A topsoil balance should be submitted for this <br />operation. <br />7. Has MCC contacted the Colorado Division of Wildlife and U.S. <br />Fish and Wildlife Service regarding the effects on wildlife <br />that may be caused by the proposed disturbances? <br />SLOPE STABILITY <br />I have enclosed a memo written to me from Bruce Stover of our <br />office. MCC should address his concerns regarding the slope <br />stability analyses performed for the materials storage bench. <br />HYDROLOGY <br />1. MCC should provide copies of Tables 42, 43, and 44 to be <br />incorporated into Volume 1 of the permit. However, it may be <br />advantageous if these tables were provided after the tables in <br />Exhibit 66 are finalized. <br />