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J. J. Dudash -4- October 01, 2009 <br />changed. The operator states that the gob piles cover approximately 34 acres <br />and the topsoil piles cover approximately 2.3 acres. The increase in the area of <br />Gob Piles #1 and #4 (of approximately 1 acre) and any changes to the area of <br />the topsoil stockpile by Gob Pile #4 will need to be accounted for in these totals. <br />These numbers will need to be changed accordingly to account for the changes <br />in the configuration of Gob Pile #4. <br />BRL - Please see revised second paragraph on Page 11 (Volume IX). The <br />topsoil stockpile acreage to be revegetated has not changed from what is shown <br />on the approved page 11. <br />13. DRMS - Based on the Division's calculation that the area of Gob Piles #1 and #4 <br />increased by approximately 1 acre, and based on BRL's statement that 36.3 <br />acres require reclamation (Volume IX, Page 11), the Division believes that there <br />may be a topsoil deficiency for final reclamation of the gob piles and associated <br />areas. BRL states that one foot of topsoil will be placed over three feet of subsoil <br />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 <br />believes that with the increased size of Gob Piles #1 and #4, there are 37.3 acres <br />requiring reclamation. For a flat area the topsoil required to cover these areas to <br />a depth of one foot is 60,200 cubic yards, a deficiency of 3,300 cubic yards (or <br />0.7 inches). The surface area for the 3:1 and 2.5:1 slopes of the gob piles will be <br />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 <br />revise the topsoil replacement plan as necessary. Note, there does not appear to <br />be a problem with the subsoil for the gob piles and associated areas as there is <br />an excess of almost 40,000 cubic yards of material. <br />BRL - The Division is correct. Based on the increased area of the Gob Piles, the <br />depth of topsoil will be reduced to 0.9' and the coverfill will be increased to 3.1 <br />feet in order to obtain the required 4' of cover. Please see revised Appendix A <br />for topsoil salvage and distribution details. In addition, the SurvCadd volume <br />listed for the topsoil piles was revised based on current pile. <br />14. DRMS - Based on a review of proposed Maps 15-3, Sheet 3 of 4, Mine Facilities <br />and Volume IX, Figure 1, Coal Mine Waste Disposal Area, there appears to be a <br />possible increase in the disturbed area of the mine. There is an undisturbed area <br />that is surrounded on the west by Gob Pile #1, on the east and south by topsoil <br />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 <br />digitized this area and found that it decreased from 1.65 acres to 1.05 acres. <br />Additionally, there is a small area to the north of Gob Pile #4 where the pile has <br />pushed into the undisturbed land above (as the piles maximum height increases <br />and its shape changes from an angular one to a more rounded one). Please <br />review the changes to the pile as they relate to the surrounding undisturbed <br />lands and update the revision application to reflect any changes as necessary.