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Page 3 of 5 <br />suitability criteria, or "Fair" in the case of Texture Class. So while the properties of the <br />two materials are not numerically equal, according the established criteria for topsoil <br />suitability, they are considered equal. <br />DRMS: BRL, in response to DRMS adequacy concerns, indicates that only coverfill <br />material was placed on the gob pile #1 and the first bench of gob pile #2 and that no <br />topsoil is intended to be replaced in these areas. However, during the May 30, 2013 <br />meeting at DRMS it was stated that some topsoil has been placed on these benches. <br />BRL was unable to indicate the depth or location of topsoil that was replaced on these <br />areas. Given the "coverfill" samples were taken from the first bench of gob pile #2 to <br />justify its use as a soil substitute it is likely that topsoil was included with these samples <br />which nullifies the analyses and justification for its use as a substitute. To justify the use <br />of coverfill as a substitute topsoil material, BRL must take samples of coverfill directly <br />from the coverfill stockpile at various locations and depths of the pile and run lab <br />analyses on new samples to be used as justification for its use as a <br />replacement /substitute for the topsoil. <br />5. DRMS: Given the deficiency in the available topsoil to be salvaged in the Gob Pile #2 <br />expansion area, the depth of coverfill and topsoil replacement will need to be revised in <br />the Reclamation section of Volume IX of the permit. Please update the topsoil <br />replacement discussion in the reclamation plan section beginning on page 14 of Volume IX. <br />Also, please update the material balance worksheet submitted in Appendix A of Volume IX. <br />BRL: Please see revised Volume IX pages 14 -19 Appendix A. In addition, DRMS requested <br />after the completion of TR -76 that Bowie add a figure to correspond to the detailed design <br />information shown on page 4, so please see new page 4i. Page 7 was updated to <br />incorporate more up to date information including referencing the topsoil variance <br />approved with TR -76. <br />The salvage volume shown on Appendix was left the same, with a note added to indicate <br />values calculated are estimated. The reclamation volumes are calculated to match the <br />volumes actually in place at the topsoil stockpiles. <br />As can be seen in Appendix A, it was estimated that approximately 72,600 CY of topsoil <br />material would be salvaged. However, the amount actually salvaged, to date, is <br />approximately 42,500 CY, forty percent of the estimated salvage volume. Discrepancies <br />between estimated and actual salvage volumes has occurred since the beginning of the <br />disturbance associated with the mining operation. As discussed on page 2.05 -51, reasons <br />for the discrepancy in estimated versus actual topsoil volumes include rocky soils, steep <br />terrain and difference in actual versus projected topsoil depth. <br />Phasing of reclamation and topsoil replacement necessarily has to change due to how the <br />pile is being constructed, and therefore how it will be reclaimed. Due to circumstances <br />beyond Bowie's control, they have to continually revise their gob pile plans at the gob pile <br />#21#4 location until an air permit can be secured for gob pile #3. Bowie does not have a <br />high level of confidence that an air permit will be issued in the near future, and therefore is <br />