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13. Based on the Division's calculation that the area of Gob Piles #1 and #4 increased by <br />approximately 1 acre, and based on BRL's statement that 36.3 acres require reclamation (Volume <br />IX, Page 11), the Division believes that there may be a topsoil deficiency for final reclamation of <br />the gob piles and associated areas. BRL states that one foot of topsoil will be placed over three <br />feet of subsoil for final reclamation (Volume IX, Page 11, first paragraph). BRL also states that <br />there is approximately 56,900 cubic yards of topsoil for reclamation. The Division believes that <br />with the increased size of Gob Piles #1 and #4, there are 37.3 acres requiring reclamation. For a <br />flat area the topsoil required to cover these areas to a depth of one foot is 60,200 cubic yards, a <br />deficiency of 3,300 cubic yards (or 0.7 inches). The surface area for the 3:1 and 2.5:1 slopes of <br />the gob piles will be greater than the flat area of 37.3 acres, leading to a greater topsoil deficiency. <br />Please review the topsoil balance for the gob piles and associated areas and revise the topsoil <br />replacement plan as necessary. Note, there does not appear to be a problem with the subsoil for <br />the gob piles and associated areas as there is an excess of almost 40,000 cubic yards of material. <br />14. Based on a review of proposed Maps 15-3, Sheet 3 of 4, Mine Facilities and Volume IX, Figure 1, <br />Coal Mine Waste Disposal Area, there appears to be a possible increase in the disturbed area of the <br />mine. There is an undisturbed area that is surrounded on the west by Gob Pile #1, on the east and <br />south by topsoil stockpiles and on the north by Gob Pile #4. The expansion of Gob Pile #4 to the <br />south (to the lower elevation) pushes into this undisturbed area. The Division digitized this area <br />and found that it decreased from 1.65 acres to 1.05 acres. Additionally, there is a small area to the <br />north of Gob Pile #4 where the pile has pushed into the undisturbed land above (as the piles <br />maximum height increases and its shape changes from an angular one to a more rounded one). <br />Please review the changes to the pile as they relate to the surrounding undisturbed lands and <br />update the revision application to reflect any changes as necessary. <br />15. Based on a review of Volume IX, Figure 1, Coal Mine Waste Disposal Area, the horizontal scale <br />of the inset cross-section B-B' has been changed and appears to be in error. The horizontal scale <br />on the currently approved figure is shown as 40 feet/inch. The horizontal scale on the revised <br />figure is shown as 100 feet/inch. This changes the length of the cross section from 600 feet to <br />1,500 feet. To further complicate the issue, based on the scale of the small map showing the gob <br />piles, at 200 feet/inch, cross-section B-B' is only 300 feet long (1-'h inches). Based on the 2:1 <br />slope indicator on the "Proposed Ground Surface" line for cross-section B-B', it appears as though <br />the correct horizontal scale should be 20 feet/inch. Please check the B-B' cross-section line and <br />detail and correct the scale as necessary. <br />16. Based on a review of Volume IX, Figure 1, Coal Mine Waste Disposal Area, the horizontal scale <br />of the inset cross-section C-C' has been changed and appears to be in error. The horizontal scale <br />on the currently approved figure is shown as 40 feet/inch. The horizontal scale on the revised <br />figure is shown as 100 feet/inch. This changes the length of the cross section from 800 feet to <br />2,000 feet. To further complicate the issue, based on the scale of the small map showing the gob <br />piles, at 200 feet/inch, cross-section B-B' is only 400 feet long (2 inches). Based on the 2:1 slope <br />indicator on the "Proposed Ground Surface" line for cross-section C-C', it appears as though the <br />correct horizontal scale should be 20 feet/inch. Please check the C-C' cross-section line and detail <br />and correct the scale as necessary. <br />3