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~ ~ • <br />-a- <br />Permanent channel reconstruction associated with the east and west draws <br />which converge at the mine site is discussed on pane 2.05.6(7). A <br />typical channel cross section illustrating design dimensions as well as <br />granular bedding and riprap specifications is referenced in the text as <br />© ~ being included in Exhibit A. The referenced cross section could not be <br />found in Exhibit A or elsewhere in the application, and an appropriate <br />cross section will need to be submitted for inclusion in Exhibit A. An <br />acceptable cross section was suggested by the Division in a letter of <br />April 21, 1987. <br />6. Soil resource information and topsoil salvage and replacement plans as <br />presented in the permit application are somewhat confusing, and raise <br />several issues of concern. The situation is summarized below. <br />At some time in the past, a quantity of topsoil and or overburden was <br />salvaged and placed alona_ the floor of the southeast draw above the mine <br />site. In a letter dated February 23, 1987, from Cliff Schmidt to NKC, <br />and received by the Division March 10, 1987, he states, "As you know, we <br />have approximately 4200 yd3 of topsoil in the canyon floor east of the <br />mine area. All this soil is within 1200 feet of the area that needs to <br />be reclaimed ... [The] remaining 2500 yd3of topsoil will be hauled from <br />the mesa just south of the mine area." <br />An October, 1989 Division inspection confirmed the estimated Quantity of <br />salvaged material in the draw, although we estimated that the average <br />haul distance from the storage site to the facilities area would be <br />m <br />~ <br />~ <br />approximately 2000 feet (See Attachment 1). Topsoil signs had been ~ <br />,,;~~ <br />erected on the stockpiled material, which was a rocky soil with minor ~'S. f-i:•i <br />amounts of coal and carbonaceous shale. ~~ <br />C.l,. <br /> ~~ .l <br />~ <br />In a number of instances within the permit application, it is stated ~ <br />that <br />an average 6" depth of soil will be replaced on the regraded slopes Sk"''' <br />within the 8.36 acre surface disturbance area (6700 yd3 of soil). Th is <br />is probably not realistic, since the volume of material stored in the <br />east draw would only provide for an average replacement depth of <br />approximately 4 inches, and the application does not propose that <br />additional soil be salvaged from undisturbed areas. <br />The following Questions need to be addressed and appropriate revisions <br />submitted. <br />a. What is the source of the soil material stored in the southeast <br />draw above the mine site and when was it placed in that location? <br />The findings of compliance indicates that the salvage operation may <br />have occurred in 1981, prior to shop construction, but no <br />confirmation could be found in the application or the Division <br />files. <br />b. The topsoil storage area should be designated as a disturbed area <br />and a plan for reclamation of the area will need to be submitted. <br />The disturbed area acreage total should be appropriately revised, <br />and disturbed area boundaries should be delineated on the (4ine <br />Surface Drainage Map (Map C-4) and the Reclamation Flap (Mao C-7 ). <br />