2011-12-06_REVISION - C1980001 (3)

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III. Topsoil A. The Division previously approved a variance from topsoil removal in accordance with Rule 4.06.2(2)(a) for steep slope areas of the eastern portion of the Moffat Area. Some portions of the West Ridge Area were mined prior to August 3, 1977, and no topsoil was salvaged. Spoil, and what topsoil was available, were seeded. Steep slope variances were also approved for portions of the West Ridge Area. Details on these variances can be found in Section 4.3.1 and in Exhibits 4.3 -1 and 2 -3.1 of the PAP. B. The Division previously waived the requirement for clearing vegetative cover prior to topsoil removal. The applicant has demonstrated that inclusion of vegetative material in salvaged topsoil is necessary or desirable to ensure soil productivity consistent with the post- mining land use. The operation utilized a rotoclear technique for removal of vegetation. The rotoclear method chopped standing vegetation, which was then incorporated into the salvaged topsoil (PAP,-Page 4.3 -1). IV. Sealing of Drilled Holes and Underground Openings A. The Division finds that each hole, well or other underground opening has been, capped, `sealed, backfilled or otherwise properly managed (Rule 4.07.3). V. Backfilling and Grading A ' The Division has previously approved,the retention of box cut spoil or initial cut spoil outside the pit area since . the applicant demonstrated that such material is not required to achieve approximate original contour in accordance with - Rule 4.09.1. Spoils from the initial box cut at the Moffat Area were cast southward onto previously Center Ridge spoils. The area was mined prior to August 3, 1977, and no •topsoil was salvaged. Spoils were graded and revegetated [Rule 4.14.1(2)(d)]. B. In order to conserve soil moisture, ensure stability, and control erosion on final graded slopes, the Division has previously approved 14 cut - and -fill terraces for the previously mined West Ridge area'. These terraces are mining completed since the enactment of SMCRA (PAP, page 2.5B -4 of Appendix 2 -.5B). . 9. Duration of elevated dissolved solids in leachate — Continuing elevated concentrations of TDS in leachate, now several years since mining ceased, is consistent with predictions that such elevated concentrations are predicted for a few hundred years (annual hydrology reports). Page 4 o Appendix 4.6 -M in Volume 1.1 a of the PAP C1980-001 Edna Mine Permit Renewal No. 6 X26