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Mike Boulay <br />March 8, 2013 <br />14. DRMS: The Operator has made a case for not monitoring deep bedrock <br />groundwater down gradient of the permit area due to the economic and technical <br />impracticality of installing wells in areas of rugged terrain and excessive overburden <br />combined with low transmissivity values and an overall lack of groundwater at these <br />depths. Based on our review of the permit document and revised pages submitted for <br />PR -2 it appears that the only data available for bedrock groundwater is limited to water <br />level information. The Division cannot locate the bedrock water quality data referenced <br />on revised page 2.04 -21. Let's plan to review the existing bedrock water quality data <br />and the need for additional monitoring during our upcoming meeting. No further <br />response is necessary at this time. <br />MCM: Text was revised on page 2.04 -20 to further substantiate the reasoning for not <br />monitoring deep bedrock groundwater down gradient of the permit area. The entire <br />Section 2.04 -7 will be included as the page numbering has changed. <br />24. DRMS: The text on Page 2.04- 33(1)(c) refers to Figure 4.4 -2 for the soil sampling <br />locations. Figure 4.4 -2 submitted with the PR -2 application on November 1, 2010 <br />delineates the water sampling locations. The text should refer to Appendix T - Figure 1 <br />for the soil sampling locations for the proposed expansion area. Please amend the <br />text on page 2.04 -33 to refer to the correct figure. <br />MCM: Please see revised page 2.04 -33. <br />65. DRMS: When comparing the Topsoil Salvage Volume chart on page 2.05 -26 and <br />the Topsoil Replacement Volumes chart on page 2.05 -27, it shows that the final <br />distribution of the topsoil will be significantly different than the salvaged distribution. <br />Please clarify the rationale of the topsoil re- distribution plan. Some of the topics <br />that should be discussed (or reference the appropriate section of permit): 1) In <br />the Greasewood Flats area an average of 24 inches of topsoil will be salvaged but <br />only 12 inches of topsoil will be replaced. Will the Greasewood Flats area, with <br />half of the original soil volume, be able to achieve the vegetation requirements of <br />the post mining land use, 2) the office area is to receive 24 inches of topsoil but <br />no salvage volumes are given for this area. How much topsoil (and depth) was <br />salvaged from the office area and where is the soil now (if disturbed pre - SMCRA, <br />include in the discussion), 3) the chart on page 2.05 -27 indicates that the office <br />area is an AVF. Also discuss how the functions of the AVF are going to be <br />restored with 24 inches of topsoil, or reference the appropriate section of the <br />permit. <br />MCM: The topsoil replacement depth have been revised, an average of 14.4 inches will <br />be replaced. Please see revised page 2.05 -27. Fourteen inches should be adequate to <br />establish the vegetative requirements of fish and wildlife and rangeland post mining land <br />uses. <br />