2009-12-11_REVISION - C1981019 (3)

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On 3 July 2006 the Division approved Colowyo's Permit Revision 02 (PR-02), which was the new South Taylor Pit mine plan. As a part of the PR-02 approval the Division attached a number of stipulations on the permit. One of these stipulations was Stipulation 8, which required Colowyo to submit technical revision for a new reclamation plan for the West Pit and the South Taylor Pit. Colowyo submitted this revision as Technical Revision 72 (TR-72). After four rounds of adequacy the Division approved TR-72 on 24 June 2009. There were two outstanding issues that were not resolved with TR-72. These issues were a variable topsoil replacement depth for the West Pit and South Taylor Pit and tall mountain shrub and aspen planting areas in the South Taylor Pit area. These two unresolved issues were attached to the permit as Stipulations 12 and 13, respectively. Colowyo has submitted Technical Revision 82 to address the variable topsoil replacement depth plan for the West Pit and South Taylor Pit and to satisfy Stipulation 12. As with the original variable topsoil replacement plan presented in TR-72, the Division believes that the overall concept is good. The original plan lacked detail and specificity. Any variable topsoil replacement plan in the Colowyo permit must have enough detail and specificity to ensure compliance in the field. While the Division does agree that there needs to be a degree of flexibility in any reclamation plan, the original Colowyo submittal was too general to meet the criteria of a verifiable plan. While Colowyo has, with the submittal of TR-82, added more specificity and detail to the variable topsoil replacement plan, additional specificity to ensure compliance is required. Rule 2.05.4 - Reclamation Plan 1. Throughout the revised text on permit pages 2.05-46 through 2.05-50, Colowyo discusses several generic terms including " thin topsoil", "gradually thicker topsoil", "deeper application down slopes", etc. While the general concept of these terms is understood, they are open to the interpretation of the reader. Please define and include a quantitative description of the topsoil replacement zones for both the West Pit and the South Taylor Pit where these zones are discussed in the permit text (for example, the second paragraph on Page 2.05-46 is the first discussion of the variable topsoil replacement zones). a. For the West Pit Area, the plan will include at least two primary replacement zones of defined replacement thickness range and a pit-wide average. Average replacement thickness for the shallow replacement zone wilt be no less than 4 inches, and the average thickness for the two primary replacement zones will differ by at least 6 inches. Colowyo's Response: a) Colowyo provided Figure 2.05-5 to identify potential candidate areas for Sagebrush Steppe establishment based on areas expected to exhibit slopes of