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r • <br />Mr. Rick Mills <br />Ms. Carol Pahlke <br />May 18, 1979 <br />Page Two <br />As you are aware, the original permit provided fora haul road with an <br />average width of sixty feet. The pioneer road installed in 1978 is cur- <br />rently being improved to the permit width. The Rockcastle Company would <br />have waited for better weather conditions to widen the haul road, but <br />due to a recently issued Colorado Division of Mines safety order, they <br />have begun improving the road already. In order to minimize the impact <br />of construction and to minimize loss of topsoil, the Rockcastle Company <br />has retained a soil scientist, Mr. Jim Walsh, to analyze soils in the <br />areas of the road to be widened and provide recommendations for reclama- <br />tion and stabilization of cut areas. Mr. Walsh's report will facilitate <br />compliance with the regulations. During your field inspection of May 11, <br />1979, Jim Walsh and Roger Funston of your staff discussed Mr. Walsh's <br />recommendations and you observed Mr. Walsh's field markings and field <br />techniques. Based on preliminary field approval given at that time, the <br />Rockcastle Company is effecting topsoil removal and reclamation in the <br />area of the road to be widened. You will receive additional information <br />as soon as Mr. Walsh's report is available (probably within two weeks <br />pending return of analytical results from the laboratory). <br />With regard to the status of other topsoil handling procedures, as you <br />observed on May 11, topsoil stockpiles on the edge of the highwall in <br />pit B-1 have been properly marked "topsoil" and will be used in reclama- <br />tion/topsoiling of reclaimed area B-1. Topsoil on the edge of pit B-2 <br />which was not scraped clean before construction of the highwall has been <br />salvaged using the backhoe with a 35 foot reach. As you know, the incle- <br />ment weather has prevented wholesale stripping of the advancing highwall. <br />Mr. Plallory has tried several times to strip topsoil from larger areas in <br />front of the advancing highwall but his equipment has sunk to the axles <br />on each try. As soon as weather permits, Rockcastle will continually <br />strip topsoil from at least one cut-width in front of the advancing high- <br />wall as explained in Exhibit D of the permit. <br />The original permit required the Rockcastle Company to salvage a uniform <br />14" of topsoil from all areas to be mined and redistribute this soil to <br />a depth of 12" over reclaimed areas. However, to comply with the federal <br />regulations, Mr. Mallory has been saving all topsoil (the dark organic <br />top layer). Mr. Mallory said the topsoil has been averaging about two <br />feet thick. <br />With respect to sediment control measures, as per the addenda to the permit <br />application, the Rockcastle Company has installed straw dikes within the <br />haul road ditches. These dikes are chicken wire cradles weighted on the <br />bottom with large rocks. Hay is then placed loosely within the cradles to <br />