2012-08-21_REVISION - M1980244 (32)

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12. Table 5 -4 Growth Medium Stockpiles indicates there will be an estimated 3,227,198 yd' of topsoil available for use in reclamation. However, Section 12.2 of Volume I states there is approximately 3.4 million yd' of topsoil available for reclamation. Please clarify this discrepancy. RESPONSE: Table 5.4 is the best available information at the time of thepermit application submittal, and the amount of growth medium available for reclamation is approximately 3.2 million cubic yards. Section 12.2 will be changed accordingly and included as Attachment 6 13. The footnotes for Table 5 -4 Growth Medium Stockpiles indicate that Stockpile 4 will be comprised of Stockpiles 2, 3, 20, and 36. The associated comments for Stockpile 36 state the stockpile will likely be relocated or used in concurrent reclamation. If Stockpile 36 will be added to Stockpile 4, then the comments should be revised to reflect this. In addition, the associated comments for Stockpile 21 state the stockpile will be added to Stockpile 4; however, the table footnotes do not indicate this. Please revise Table 5 -4 Growth Medium Stockpiles accordingly. RESPONSE: As the Division is well aware, reclamation is a dynamic, ever- evolving process that depends on many factors including the proximity of the growth medium to the site where it will be replaced. CC &V diligently tracks the location of the growth medium piles and strives to locate them near the anticipated replacement areas. In this case, it is anticipated that stockpile 36 will indeed be used up in reclamation to avoid "double- handling" but if not feasible, portions may have to be relocated to stockpile 4. The same situation exists for the small stockpile 21; it most likely will be direct - hauled to a reclamation area but, if not feasible, then will be relocated to stockpile 4. A revised Table 5 -4 is included as Attachment 6 to reflect this clarification. 14. On page 12 -14 of Volume I, the Applicant has stated other material containing fines will be used to cover the overburden placed as backfll if stockpiled growth medium is not available. Table 5 -4 Growth Medium Stockpiles indicates there will be an estimated 3,227,198 yd3 of topsoil available for use in reclamation, which exceeds the estimated 2.4 million yd of topsoil required for reclamation. Please provide a technical justification as to why fines would be used to cover backfilled overburden when it appears there will be an excess of suitable growth medium. RESPONSE: In the past, there have been instances where there was insufficient topsoil salvaged and other plant growth medium (i.e., fines) was used Fines, in this context, refers to overburden rock of fine texture (smaller grain size) obtainedfrom near - surface development offacilities at the Cresson Project. This material is "finer" than the typical larger sized material obtained from the deeper development of facilities at the Cresson Project. CC &V has tested this material and it has been proven successful in reclamation practices to date that the "finer" material serves very well as a material to fill in the void space associated with reclamation of the larger overburden material. CC &V intends to utilize growth medium from stockpiles wherever possible, but in certain situations it may be more beneficial to achieve successful final reclamation by utilizing the "fines" as an alternative material. Prior to using "fines" as a replacement for growth medium, CC& V will test the materials and will demonstrate to the Division why such materials will be used. Even though an approximate volume of 3.2 million yd' of growth medium are identified to be available for reclamation of the Cresson Project, in some instances this finer material may be located in closerproximity to a reclaimed area and may be used as an alternative to salvaged materials given prior success. 15. The Applicant has stated topsoil will be replaced over disturbed areas at a depth of 6" or less. Operators are encouraged to allow flexibility in their reclamation plans by committing themselves to a range of numbers (e.g., 6" — 12 ") rather than specific figures. The Division requests the Operator commit to replacing topsoil at a depth of no less than 6 ". Please specify the range of depths to which topsoil will be replaced. RESPONSE. Prior amendment applications reviewed and approved for the Cresson Project have referenced a depth of 6" or less for which the Division accepted. Thus, CC &V is uncertain why the same language no longer is acceptable to the Division. CC &V has evaluated salvageable amounts (see question 14) and given the amounts identified as being available, CC &V will agree to the Division's request and commit to replace growth medium at a depth of no less than 6- inches during reclamation activities at the Cresson Project.