2008-12-10_REVISION - C1981010 (3)

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Knight Piesold C O N S U L T I N G Mr. Jason Musick December 10, 2008 Environmental Protection Specialist Response: The reclamation liability has been recalculated. The worst case year remains 2012 when the largest area of K pit has been excavated with minimal direct haul backfill. In order to bring the configuration of this pit to an acceptable state in the unlikely event that operations cease in 2012, material from the Horse Gulch Fill is hauled to backfill the open area and dozers are utilized to better balance the material in and adjacent to the pit. Revised K pit cross sections for inclusion in Appendix A have been enclosed for reference. In addition, Map M6, Bond Worst Case Year, and Section 1.4, Determination of Bond, page 1-31 and Tables 1.4-1 through 1.4-7 have been revised and are resubmitted. The reclamation liability now totals $28,494,973 compared to $22,250,743 in the original submittal. Division Response No. 4 pertaining to sediment control issues in Deal and Horse drainages: This response is complete. Response: Subsequent to the Division's letter of February 15th, Trapper pulled the Horse Gulch enlargement from PR-6 and included it with TR-103 so that the work could take place during the summer of 2008. This work has been completed and the certification of the as-built was submitted under a letter dated September 12th. Tables 4.8-6 and 4.8-7 have been updated to reflect the as-built configuration and are enclosed with this submittal. Division's additional items required to find the PR-06 application complete: 1. Please describe how K pit spoil will be transported to the proposed Horse Gulch and K Area buttress fills. Please be aware that Rule 2.05.3(3)(c) requires a description of each road ...to be constructed, used or maintained within the proposed permit area. Please be aware that Rule 2.05.3(3) additionally requires this description to include a map prepared in accordance with Rule 2.10 to include appropriate cross sections, and to include the items specified in Rules 2.05.3(3)(c)(i)-(vl1). Response: Haulroads are addressed in Section 3.7.2 of Trapper's permit document. The text in this section has been modified slightly to incorporate references to waste hauling as well as coal hauling. The revised text is enclosed. Map M9, Haulroads, Sheet 3, has also been modified to show haulroads to the fill areas. Figure 3.7-1, Typical Haulroad Cross-Section, is referred to in Section 3.7.2.2 and continues to apply to all haulroads. 2. In accordance with the requirements of Rules 2.05.3(5), 2.05.4(2)(d) and 4.06, please provide narratives explaining the methods of topsoil removal, the amounts of topsoil to be removed, the plans for storage of salvage topsoil and the plans for redistribution of topsoil for the K-Pit, Horse Gulch Fill and K Area Buttress Fill areas. DV 102.00302.01 3 PR-6 Completeness Response Ltr