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C- 2010 -089 NHN Mine 20- Oct -2011
<br />PAR No. 2B Page 6 of 7
<br />b) The WyDEQ guideline, in Appendices 11 and III, contains excellent examples of topsoil
<br />and overburden balance calculations. Please review these examples and provide
<br />exhibits of comparable detail for inclusion in the application.
<br />16. Single -lift salvage and replacement of topsoil is currently proposed for all soil types that will
<br />be disturbed (per first paragraph on page 26 of Section 2.04.9, and the Topsoil Stripping
<br />subsection on page 12 of Section 2.05.4(2)(d)). The Division has conducted additional
<br />analysis of soil availability, based on information presented in the table on Map 2.04.9 -3.
<br />The results are tabulated here; for your review.
<br />*Includes 78UT, Rock Outcrop, Ponds, Ditches, DC -1, Roads
<br />The 81/82 Progresso soils (in green) comprise the largest soil type within the proposed
<br />permit area: nearly 109 acres. These soils are markedly thicker (at 342" on average) than
<br />are the 77/78 Pinon soils (88 acres, at 12.1 ") or the previously redistributed REC soils (-75
<br />acres, at 17.2" ).
<br />Western Fuels' proposed justification for single -lift salvage is provided beginning on page
<br />12 of Section 2.05.4(2)(d). The reasons given include the "relatively shallow" soil
<br />thicknesses, and the large equipment that will be used in salvage operations. The next
<br />paragraphs refer to reclamation research conducted by CSU, and others. The Division does
<br />not believe the referenced research is relevant to the issue of topsoil salvage and
<br />replacement for reclaimed pasturelands, and that the three research papers should be
<br />removed from the application.
<br />While single -lift salvage may be appropriate for the thinner 77PIN, 78PIN, and REC soils,
<br />the Division remains unconvinced that salvaging 81PRO, and 82PRO soils in a single lift,
<br />and mixing them with the other soils, will ensure that the reclamation plan and post mining
<br />land use will create a productive irrigated pasture. The requirements of Rule 2.05.5(1)
<br />require; "a detailed narrative of the proposed use, following reclamation of the land In
<br />accordance with land use categories established in the narrative, the plan shall include a
<br />discussion of the utility and capacity of the reclaimed land to support a variety of alternative
<br />uses, and the relationship of the proposed use to existing land use policies and plans." Sub-
<br />paragraph (iii) requires an explanation of the consideration which has been given to the
<br />landowners' plans and programs. Furthermore, Rule 4.16.1(1) requires that, "the reclaimed
<br />Volume
<br />Average
<br />Combined
<br />Net
<br />Soil
<br />Area
<br />Area
<br />(Bulk
<br />Thickness
<br />Area/
<br />Thickness
<br />Type
<br />(,Sq.Ft.)
<br />(Acres)
<br />Cu. Yds)
<br />(inches)
<br />Thickness
<br />(inches)
<br />3'76
<br />U
<br />163,695
<br />3.76
<br />15,995
<br />31.7
<br />Acres
<br />31...:.7
<br />74'67 Acres
<br />REC
<br />3,252,709
<br />74.67
<br />173,007
<br />17.2
<br />17.2"
<br />280.83 '
<br />3,483,742
<br />79.98
<br />130,414
<br />Acres
<br />350,924
<br />8.06
<br />12,460
<br />81PRO
<br />4,267,046
<br />97.96
<br />447,226
<br />34.0
<br />108,98 Acres
<br />34.2"
<br />22.1"
<br />82PRC} '
<br />480,049
<br />11.02
<br />54,092
<br />36.5
<br />5.39 Acres
<br />Other*
<br />234,622
<br />5.39
<br />0
<br />0
<br />0.0
<br />*Includes 78UT, Rock Outcrop, Ponds, Ditches, DC -1, Roads
<br />The 81/82 Progresso soils (in green) comprise the largest soil type within the proposed
<br />permit area: nearly 109 acres. These soils are markedly thicker (at 342" on average) than
<br />are the 77/78 Pinon soils (88 acres, at 12.1 ") or the previously redistributed REC soils (-75
<br />acres, at 17.2" ).
<br />Western Fuels' proposed justification for single -lift salvage is provided beginning on page
<br />12 of Section 2.05.4(2)(d). The reasons given include the "relatively shallow" soil
<br />thicknesses, and the large equipment that will be used in salvage operations. The next
<br />paragraphs refer to reclamation research conducted by CSU, and others. The Division does
<br />not believe the referenced research is relevant to the issue of topsoil salvage and
<br />replacement for reclaimed pasturelands, and that the three research papers should be
<br />removed from the application.
<br />While single -lift salvage may be appropriate for the thinner 77PIN, 78PIN, and REC soils,
<br />the Division remains unconvinced that salvaging 81PRO, and 82PRO soils in a single lift,
<br />and mixing them with the other soils, will ensure that the reclamation plan and post mining
<br />land use will create a productive irrigated pasture. The requirements of Rule 2.05.5(1)
<br />require; "a detailed narrative of the proposed use, following reclamation of the land In
<br />accordance with land use categories established in the narrative, the plan shall include a
<br />discussion of the utility and capacity of the reclaimed land to support a variety of alternative
<br />uses, and the relationship of the proposed use to existing land use policies and plans." Sub-
<br />paragraph (iii) requires an explanation of the consideration which has been given to the
<br />landowners' plans and programs. Furthermore, Rule 4.16.1(1) requires that, "the reclaimed
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