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Susan Burgmaier, DRMS <br />April 11, 2013 <br />TR77; Review Memo <br />Plant Rvvegetation Guide for Colorado, " indicates a soil in an upland community with and SAR value of less and 6 <br />is considered suitable and good. <br />Conclusion <br />The coverfill material is comparable in terms of suitability to the topsoil that was originally found in the gob pile #2 <br />area. While there are differences in physical and chemical composition, it does not appear the characteristics of the <br />coverfill material will negatively impact the establishment and development of the desired species. The coverfill <br />material resembles the soil material found in the gob pile #2/4 area based on the NRCS soil unit description for this <br />area. Given the lack of salvageable topsoil material in portions of the gob pile 42 expansion area, the coverfill <br />material is the best available material in the area to support revegetation. All salvageable topsoil material should <br />continue to be salvaged and all topsoil that is salvaged will need to be replaced on the reclaimed lands. The coverfill <br />material should be use as a supplement to the available topsoil and not necessarily used as a replacement to topsoil <br />that is available and could have been applied to the reclaimed area. The wording of this should be clear in the pages <br />BRL is proposing to revise in their permit. The coverfill material should only be considered as a replacement to the <br />topsoil that was not salvageable in accordance with the variance approved in TR76. Given this, there are several <br />adequacy review items that should be clarified prior to Division approval of the TR77 application. <br />Adequacy Items <br />1) Revised page 2.04 -101 submitted with TR77 indicates that select overburden materials may be used as a <br />replacement and or supplement to the topsoil on the coal mine waste piles. The language used should be <br />updated to specify "coverfill material" may be used as a supplement to the topsoil material as this is the <br />only type of overburden material that was evaluated and considered for this use. Other types of <br />overburden material will need to be analyzed in the future and the justification and test result submitted <br />to the Division for approval in order for it to be used as a replacement and or a supplement to topsoil in <br />accordance with Rule 4.06.2(4). <br />2) The first sentence of item (3) on revised Page 2.04 -101, should be updated to clarify that the coverfill <br />material will only be used to "supplement" the available topsoil material to be replaced. The coverfill <br />material should only be considered as a replacement to the topsoil that was not salvageable in <br />accordance with the variance approved in TR76. <br />3) The first sentence of item (3) on revised Page 2.04 -101 should specify that coverfill material will be used <br />to supplement the topsoil to be replaced on the gob pile #2/4 area where the topsoil deficiency exists. <br />The submitted revised page broadly states that substitute material will be utilized on coal mine waste <br />piles and this material may not be the most suitable for all areas where coal waste is stored depending on <br />the topsoil that is available in those areas. <br />4) The third paragraph of item (5) on revised page 2.05 -50 should be revised to specifically state that <br />"coverfill material" will be used to supplement (not replace) the topsoil on the gob pile #2/4. <br />5) Given the deficiency in the available topsoil to be salvaged in the gob pile #2 expansion area, the depth <br />of coverfill and topsoil replacement will need to be revised in the Reclamation section of Volume IX of <br />the permit. Also, the material balance worksheet submitted in Appendix A with Volume IX will need to <br />be updated. <br />6) Map No. 32; Topsoil Distribution Plan, may also need to be updated to account for the deficiency of <br />salvageable topsoil in the gob pile #2 expansion area. <br />11 <br />