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Letter to Ann Beierle 2 December 17, 1998 • The difficulty and expense of reclamation of the tailing impoundment would be greatly increased if the topsoil for capping of the tailing had to be borrowed from previously undisturbed are;ts as opposed to being spread from properly situated and maintained stockpiles. The increased costs aF such a plan would necessarily have to be reFlected in the financial warranty held by the Mined Land Reclamation Board. • Essentially, for the reasons cited above, approval of a plan that allows loss of topsoil Icy [ailing inundation may result in a greater risk that reclamation performance standards could no[ be achieved. Therefore, DMG can not approve such a change. Proposals to downgrade a reclamation plan for the purpose of reclamation cost savings could of course be presented to the Mined Land f:eclamation Board for a ruling. We also discussed the logistics of the soil salvage plan approved by the DMG via technical revision on March 21, 1991. You indicated that [he approved plan would result in materials being ex~:avated from depths as great as eight feet being mixed in and placed in the topsoil stockpiles. Based on the soil information contained in the original reclamation permit application, it is unlikely that materials excavated from depths greater than about four feet would be suitable for use as plant growth medium at the time of reclamation. Mixing of deeper, poor quality C-horizon soils into the topsoil stockpiles should be discouraged. The DMG recommends that a technical revision be provided modifying soil salvage procedures to recover only the A-horizon and acceptable quality B-horizon soil, regardless of the depths at which they occur. If such a modified soil salvage plan would result in a shortfall of plant growth medium to meet the required average 12-inch replacement depth, then a proposal to supplement soil Chickness via borrow areas or salvage of C-horizon or other materials from the tailing basin may be appropriate. Any salvaged poorer quality plant growth medium would have to be stockpiled separately front topsoil and applied to the tailing surface at the time of reclamation and prior to the replacement of topsoil in a separate earth-moving task. Finally, the two topsoil stockpiles that are in the path of tailing encroachment must be relocated at the appropriate time to prevent loss of the topsoil resource. Please note that Rule 3.1.9(4) specifies that a technical revision be filed detailing the stockpile relocation plan. If you have any questions, please contact me. Sincerely, l ~`~`~ ! Allen C. Sorenson Reclamation Specialist Cc: Carl Mount Bruce Humphries c:\wi ndows\personal\hendts.doc