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C-81-018: RN-02: B. Pavlik 2 • Contemporaneous Reclamation: Statement on pg. IV-25, "The bank slopes will be reclaimed periodically to minimize the size of the disturbed area existing at any one time." Should we be enforcing reclamation of the toe of refuse area 2/3? New page IV-51 talks about mitigation of prairie dog disturbance at the disposal area and claims that reclamation of refuse areas will be simultaneous with new area utilization. This may be an issue with the revision associated with Refuse Area SA. • SAE's: I know we're trying to get a handle on all the SAE's at Deserado. Page IV-46 (new pages) has a number of them listed. Additional ones that I thought of follow: / Halandras landfill-has a small sump at the bottom of the hill. / Are (iii) and (ix) the same areas? / (xi) Refuse area topsoil 2/3 & 4, and subsoil 2/3 & 4 are not listed. / Pg IV-12 discusses sae along conveyor above bathhouse, where the haybales are. / Explosives storage area should be included. / The two little topsoil piles south of the rail loop should be considered SAE's as well. RRTS1 and RRTS2? • To Western Fuel's credit they may want to add a comment in the wildlife section about the Pronghorn Antelope's continued use and sightings on the refuse piles. This could aid their claim that perturbation to this species will be minimal. • Topsoil replacement depths: 4 - 24 inches deep. This is dependent on regraded topography. Eighteen inches will be replaced at the refuse piles (Map 82). • The Revegetation Success section states that reference areas 0110, 0140, and 0150 will be fenced to keep sheep off. We should field check this to make sure they have done it. • Coal refuse quality, this may have already been dealt with as a result of the NOV written on compaction of the refuse piles. My concern is if they haven't done a refuse analyses since 1986 and we know that the coal quality and refuse quantity has changed significantly since 1986, has the refuse parameters changed to the point that stability factors have changed? A similar issue to this came up regarding the Southfield waste piles about 2 years ago, where they had more fines than they had designed for. It had the potential to affect pile stability. Those were mostly comments or concerns for you, not items that Western Fuels needs to respond immediately to. The following items are items of concern that should be addressed by Western Fuels during this renewal.