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a. The possible use of imported topsoil from stockpiles adjacent to the Seneca II-W <br />Tie-Across-Haul-Road once that road has been approved as a permanent road <br />(assuming it is converted to a Routt County public road). <br />b. Use of some of the topsoil used to cover nearby azea 005 with 14" of topsoil on <br />area 006. <br />c. Reallocate topsoil distribution to provide for a minimal replacement depth on all <br />areas except possible shrub establishment areas, drainage channels and permanent <br />roads. <br />d. Use of rock piles on a few acres within azea 006 to reduce the azea where topsoil <br />will be required. <br />e. Designation of less steep aeeas as locations where less topsoil will be <br />redistributed. <br />f. Possible redistribution of topsoil which was replaced in recent years in excess <br />of the required 12 inches. How much excess topsoil has been replaced on <br />previously reclaimed areas and are those aeeas adjacent to the disturbed azea? <br />9. Area 009 is listed on Table 9-9-1 and in the permit text, but is not located on Map 9-3c. <br />Please mark this area on the map. <br />] 0. Results of lab analyses of regraded spoils were submitted in conjunction with this TR. <br />Page 6-16 of the Seneca II permit includes a list of parameters for which spoils are to be <br />analyzed. Several of these parameters were apparently omitted from the analyses. <br />Regarded spoil in aeeas to be covered with topsoil will need to be analyzed as indicated in <br />the permit. It is especially important that adequate sampling and analyses be done on <br />spoils in any areas where Seneca proposes to demonstrate that the spoils are suitable <br />topsoil substitutes. <br />11. Page 13-11 of the Seneca II permit indicates that no topsoil substitutes will be used in <br />reclamation of the mine. If selected overburden is to be used as a topsoil substitute, this <br />discussion will need to be revised. In addition, the requirements of Rule 4.06.2(4)(a)(i) <br />will need to be fulfilled. In order to approve the use of substitute topsoil materials, the <br />Division would need the following information: <br />the source and quantity of substitute material, textural class and <br />percentage coazse fragments, pH, ABP, EC, SAR, saturation <br />percentage, NO,, P, K, B, Mo, Se. <br />l2. On Table 9-9-1, Seneca depicts the average topsoil replacement depth ranging from 4 <br />inches to 14 inches. The Division does not feel that an amount exceeding the approved <br />12 inches should be replaced in azea 005, especially with such a large topsoil deficit at <br />