2010-08-25_REVISION - C1981008

• Permit No: C1981008
• IBM Index Class Name: Revision
• Doc Date: 8/25/2010
• Doc Name: Adequacy Review No. 5
• From: DRMS
• To: Western Fuels-Colorado
• Type & Sequence: PR6
• Email Name: MLT
• Email Name: SB1
• Media Type: D
• Archive: No

C- 1981 -008
PR -06 AR #5
August 25, 2010
Page 12 of 26
42. The Division requested a number of clarifications to soil and seedbed preparation plans
presented in Section 2.05.4(2)(d), subsections 13.1, 13.2, and 13.3a and b. Most of the requested
clarifications were incorporated into the amended narrative. The following exceptions were
noted: In Subsections 13.2 Item 1 and 13.3a, Item 1, commitment to ripping Bench 1 surface
spoil beneath soil and spoil stockpiles, prior to topsoil spreading, was not provided. Item 5 of
13.1, 13.2, and 13.3a was changed to specify use of disking only, rather than chisel plowing and
disking, as requested. The typographical error "toughened ", in Item 5 of Subsections 13.1, 13.2,
and 13.3a, was not corrected as requested. Please make the noted corrections as requested in the
Division's July 23, 2010 letter.
42A. Previously resolved.
43. Previously resolved.
43A. The Division requested that plans be provided to address handling of competent sandstone lenses
encountered during stripping of Lift B soil or Bench 1 overburden. The concern was adequately
addressed in Subsection 13.0, with respect to topsoil or subsoil stripping. Please provide
clarification in the amended text that the specified measures (burial in lower Bench 1 overburden
replacement below the root zone) would also apply for stripping of Bench 1 overburden to be
replaced as the surface spoil layer in Zones 6 and 7.
43B. The Division requested that plans be provided to address handling of friable shale or claystone
dominated deposits in the Bench 1 overburden, and appropriate plans were provided within
amended Subsection 10.1 of Section 2.05.4(2)(d). Item Resolved
43C. The Division requested that additional narrative detail be provided in Subsection 10.0 to address
specific regulatory requirements regarding topsoil and subsoil handling approaches and
equipment, measures to avoid excess compaction, and measures to ensure replacement of
approximate uniform thicknesses for Bench 1 subsoil substitute, topsoil, and subsoil lifts.
Appropriate narrative was provided in amended Subsections 10.0 through 10.2 to address
questions regarding topsoil replacement. Details regarding soil stripping equipment and
techniques are still lacking. The appropriate sections to address the methods and equipment used
in soil salvage operations would be Section 2.04.9, Subsections 16.4 (for prime farmlands) and
16.5 (for non prime farmlands). Please include a detailed description of salvage methods and
equipment used in the stripping, loading, and transport of Lift A, Lift B, and mixed lift soils, and
Bench 1 overburden to be placed as the surface spoil layer directly beneath the topsoil.
NEW ITEMS
43D. In the second paragraph of amended Subsection 8.0 of Section 2.05.4(2)(d) revised text there is a
typo "land sue ", which should be corrected to state "land use ".
43E. In the first paragraph of amended Subsection 11.2, reference to Map 2.05.4 -9 appears to be
erroneous, correct reference would be Maps 2.05.4 -6 and 2.05.4 -7.
43F. There is a reference to Pond 13 in Subsection 12, 1.1 under the heading "Lift A Topsoil ", which
appears to be erroneous; the discussion is pertinent to the Morgan property and the reference
presumably should be to Pond 11.