2013-07-24_REVISION - C1980007 (8)

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of the SL-04 application. IV. OBSERVATIONS AND FINDINGS The following discussion of observations and findings focuses on the results of the revegetation, topsoil replacement and soil loss demonstration for the Partial Phase II Bond Release. The evaluation of the bond release application included the bond release inspection, an office review of the permit requirements and regulatory criteria and review of past inspection reports. The bond release inspection was conducted on 19-20 June and 7 August 2012. Several items including topsoil replacement, revegetation success and soil loss that were included in the bond release application were reviewed by the Division in the office during the technical evaluation of the bond release application before, during and after the inspection. Topsoil Replacement All of the reclaimed areas included in the West Elk SL-04 application were small, linear areas. In each case the topsoil was salvaged and stored locally, either adjacent to the respective drill pad or windrowed along the applicable light-use road. No soils were hauled to and stored at a common location for any of the disturbances. As such, all of the topsoil material that was salvaged from a specific location was available for the reclamation at only that location. Since all of the topsoil salvaged at a given location was replaced only at that location, the Division did not take any topsoil depth measurements, as the topsoil depths would be dependent on the depth/volume of topsoil encountered at each location (which could be highly variable). The Division’s inspection of topsoil replacement on the drill pads and light-use roads was focused on three distinct areas. First, was there topsoil present on the pad and/or road location? Second, was the topsoil replacement adequate to allow for the growth of vegetation? And third, were there any remaining piles of topsoil that were not spread on any location? The Division found that there was topsoil spread at each of the reclaimed areas. This topsoil appeared to be spread as evenly as practicable as there were no large piles or depressions on any of the reclaimed areas. The topsoil was adequate to provide a growth medium for the approved seed mix (see also the “Revegetation” section below). Finally, there were no visible piles or windrows of topsoil that remained at any of the sites. The Division finds that the West Elk Mine has replaced topsoil at all of the SL-04 locations in accordance with their approved reclamation plan and the Rules. Revegetation There were 61 locations, totaling 67.6 acres, included in the West Elk SL-04 application. A detailed list of the locations, acreages and years of reclamation can be found in the partial Phase Proposed Decision and Findings of Compliance 7 July 2013 Partial Phase II Bond Release SL-04 Page 4