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<br />-2- <br />b. The dashed line shows limits of topsoil removal by mining year. <br />The stippled area indicates where topsoil will not be salvaged <br />because of excessive slope steepness. Does the outer border of <br />these combined areas equal the "affected area" boundary? In <br />surface mines, the affected area (Rule 1.04(7)) should be equal to <br />the "disturbed area" (Rule 1.04(36)). Please also change the <br />application form to reflect this. <br />c. In reviewing the PR application it was hard to find a map which <br />clearly showed affected area boundaries and thus complied with <br />Rule 2.10.3(1 )(c ). Please state which map clearly shows the <br />affected area boundary or submit a revised one which does. This <br />will enable the Division to evaluate the topsoil salvage and <br />replacement plans. <br />7. The soil salvage plan does not clearly state how topsoil types will be <br />delineated in the field so the correct amounts will be salvaged. Please <br />describe how P8M equipment operators will tell how to determine places <br />and thickness of topsoil salvage. The Division suggests that P&M commit <br />to leaving undisturbed topsoil islands or pedestals for inspectors to <br />check in order to verify that soil is being salvaged to the extent <br />possible. Location of these islands should be one in each soil type or <br />every five acres in larger soil mapping units. Please address this issue. <br />8. P8M is planning to "daylight" through the ridgetop to the east as shown <br />on Exhibit 4.3-1, Sheet 1 of 2. How will P8M prevent material from <br />rolling farther downhill than the coal cropline? <br />9. The south topsoil stockpile footprint covers some very uneven ground. <br />Will this area be leveled prior to topsoil placement in order to minimize <br />topsoil loss upon its removal from the stockpile? Please address this <br />concern. <br />Stream Buffer Zones <br />1. Section 3.4.2.1 (Pane 3.4-2) of the proposed permit revision (PR-O1) <br />contains a statement that "This grading will leave approximately 100 feet <br />of undisturbed ground between Trout Creek and the active aradino area." <br />The currently approved statement reads "This grading will leave a minimum <br />of 100 feet of undisturbed ground between the Trout Creek Valley and the <br />active grading area." The statement contained in the proposed revision <br />is unacceptable according to Rule 4.05.18. This rule requires that "No <br />land within 100 feet or oreater distance...of a perennial stream... shall <br />be disturbed by surface coal mining operations...unless the Division <br />authorizes such disturbance upon specific findings under Rules <br />4.05.18(1 )(a-c)". Further, I was not able to locate any commitments for <br />stream buffer zone markers (made as specified in Rule 4.02) as required <br />by Rules 4.05.18(2). <br />3091E/scg <br />