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<br /> <br />The program involves conducting periodic field inspections during salvage <br />operations and adjusting topsoil recovery depths if warranted by field <br />observation tests. <br />Review of Tab 9-6 of the permit application revealed that only 6 inches of <br />topsoil was proposed for salvage from the Binco Clay Loam and Abor Clay soil <br />types (map units 11C, 11D, and 4D), even though the B horizons with a <br />thickness of 21-22 inches appeared salvageable. In light of this, the <br />Division requested that the applicant provide sufficient justification for <br />limiting topsoil salvage from these areas. The applicant responded with <br />additional information indicating that the high subsoil clay content of these <br />soil types (65g mean clay content) along with the lack of any ameloriating <br />characteristics (friable consistence, granular structure, high organic matter <br />contents and/or low to moderate saturation percentage) resulted in a highly <br />undesirable soil for use as a seed or root growth medium. Based on a review <br />of the applicant's response and literature cited by the applicant in support <br />of the response the Division concurred that the present salvage scheme for <br />these two soil types was appropriate. <br />During the review, the applicant was requested to revise the permit <br />application to provide a plan for monitoring and contour ripping of any <br />slippage surfaces identified on the final graded areas prior to the <br />replacement of topsoil. The original soil stabilization plan was limited to <br />monitoring areas already topsoil ed. In response to Division comment, the <br />applicant amended page 13-13 of the application to include regraded spoil <br />monitoring and contour ripping of spoil slippage areas in accordance with <br />Rule 4.06.4(1). <br />Peabody Coal Company is in compliance with Rules 2.04.9, 2.05.3(5), <br />2.05.4(2)(d), and 4.06. Information demonstrating compliance can be found in <br />Volume V, Tab 9, pages 9-1 to 9027, Appendices 9-1 through 9-8 and <br />Exhibits 9-1 and 9-2; Volume VII, Tab 12, pages 12-35 to 12-36 and <br />Exhibits 12-1 and 12-2, and Volume IX, Tab 13, pages 13-13 to 13-17 and <br />Exhibit 13-1. <br />XII. Vegetation - Rules 2.04.10, 2.05.4(ii)(e), 4.15, and 4.18.04(1) <br />The Division reviewed the permit application for compliance with the above <br />sections. Information on baseline vegetation for the Seneca II-W Mine permit <br />area can be found in Tab 10 of Volume YI. Information on the revegetation <br />plan and revegetation success criteria for the permit area can be found in <br />Tab 13 of Volume IX of the permit application. <br />During the course of the initial permit review, the applicant relocated the <br />then proposed haul road. The haul road relocation was the result of public <br />comment received by the Division during the initial public comment period. <br />Specifically, an adjacent landowner requested that the road be relocated in <br />order to protect his spring. In addition, Routt County was concerned about <br />the original location due to its proximity to the Hayden airport. <br />-42 - <br />