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6. Review of the reclamation plan indicates that topsoil will (or has previously been) <br />replaced on all final reclamation areas at the West Mine. Average replacement <br />depths of 8-9 inches are listed for the waste disposal area, and 24 inches for <br />certain other locations, but no narrative, table, or map that presents a <br />comprehensive listing of average topsoil replacement thickness for each logical <br />reclamation parcel (based on salvaged volume and final reclamation acreage) <br />could be located. <br />Please provide a narrative, table, or map that specifies average replacement <br />thickness for each logical reclamation parcel to be topsoiled. <br />7. The section heading at the top of page 59 (2.05.4(3)(a)) would appear to contain a <br />typographical error, and should be 2.05.4(2)(a). Please correct the heading. <br />8. The paragraph regarding rock slope entries at the bottom of Reclamation Plan <br />page 62 is apparently now out of date (since construction of the entries is no <br />longer planned). Please amend the page to delete the outdated paragraph. <br />9. In the first paragraph of Reclamation Plan page 66, it is stated that 0" to 9" of <br />topsoil were stripped and will be replaced on the remainder of the West Ridge <br />disposal area... This conflicts with statements elsewhere in the narrative that <br />indicate 8" to 9" of topsoil were stripped and will be replaced. This apparently is <br />a typographical error, and should be corrected. A plan indicating that 0" to 9" of <br />topsoil would be replaced in a given location would not be meaningful or <br />enforceable, and would not comply with regulatory requirements regarding <br />average uniform replacement thickness. Please amend the referenced <br />statement as appropriate. <br />10. There appears to be missing narrative in our version of the reclamation plan <br />narrative, between page 66A and page 67. Our page 67 (Added 07/13/87/Revised <br />07/13/87/Revised 10/01/87) begins in the middle of a sentence (the year for <br />construction of the soil berms... ), which does not flow logically from the bottom <br />of page 66A (Revised 10/25/91). Page 66B (Revised 10/25/91) is a diagram, <br />Figure 2.05-8 "Orchard Valley West Mine Livestock Trail". <br />Please provide properly amended pages for the referenced section. <br />11. At the Paonia Loadout Facility, approximately 40 acres were disturbed prior to <br />enactment of SMCRA or associated state reclamation laws and regulations. The <br />area is a "grand-fathered" alluvial valley floor, and topsoil was not salvaged prior <br />to disturbance. The AVF was flood irrigated cropland (apparently fruit orchard) <br />prior to disturbance and the predominant soil type was Aqua Fria stony loam, 3- <br />12% slopes, which NRCS has identified as a soil type that supports "Farmland of <br />Statewide Importance". <br />4