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Page 4 of 5 <br />currently planning another expansion to the gob pile #21#4 area. Where topsoil pile D &E <br />are currently located, gob will eventually be placed. (A technical Revision incorporating <br />this expansion will be forthcoming and is presented here in concept as a means to further <br />demonstrate the necessity of revising the topsoil distribution plan). <br />Removal of topsoil from piles D and E will need to be performed in one step, and then gob <br />will be replaced within in the void created in a very short window of time. In order to <br />accomplish this, the topsoil replacement depth throughout the pile will vary which is why it <br />has been demonstrated that coverfill can be used as a topsoil substitute and /or <br />replacement in some locations. <br />Phase I of topsoil replacement will be to place 0.75 feet of topsoil on the west side of gob <br />pile #4 and benches two and three of gob pile #2. After placement of topsoil on bench <br />three, the topsoil remaining in the stockpile(s) will be moved to the top of the coverfill <br />stockpile. Then, gob will be placed in the void left by topsoil stockpiles D & E. (No gob will <br />be placed in the void left by stockpiles D & E until approval from DRMS is granted. <br />Phase 11 of topsoil replacement will be to place topsoil on benches four & five, the top of <br />gob pile #2 and in the footprint of the coverfill stockpile. The replacement depth will be <br />approximately 0.5 feet. <br />Phasing of the topsoil removal and replacement with gob is an important step, as well as <br />not re- handling more topsoil than necessary. In order to accomplish these two steps, <br />topsoil will be placed on areas that are to grade and ready to receive topsoil. Then, the <br />remaining topsoil will be moved and stockpiled until reclamation of the remaining <br />benches. By phasing replacement in such a manner, disturbance of topsoil resources will <br />be minimized, and creation of a new storage location for gob will be accomplished in a <br />timely manner. A schematic of the reclamation plan with bench locations has been created <br />as is incorporated as new page App. A -2. <br />DRMS: <br />a. During the May 30, 2013 meeting BRL indicated the proposed replacement plan <br />may be further modified to place coverfill only on a portion of the second bench <br />of pile #2. If this is done the soil redistribution plan will need to be revised. In <br />regards to using coverfill material as a substitute for topsoil, Rule 4.06.2 (4)(a) <br />indicates the Division may require that results of field -site trials or greenhouse <br />tests be used to determine the feasibility of using overburden materials as a <br />substitute for topsoil. If BRL decides to modify the soil redistribution plan, and <br />only place coverfill on a portion of the second bench of gob pile #2, this area <br />should be used as a field trial site to assure the coverfill material will be equal <br />to or more suitable for sustaining the vegetation than the topsoil in accordance <br />with Rule 4.06.2(4)(a). BRL will need to prepare a trial and test plan for <br />approval by the Division; conduct vegetation sampling on this coverfill only <br />area and compare it to an area that has been topsoiled and revegetated in <br />accordance with the approved plan. <br />