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<br />Allen S. Weaver <br />Page 3 <br />October 14, 1997 <br />exists as almost a monoculture." and "sporadic and infrequent wheat grasses can be <br />seen...but in very low concentrations." <br />8/13/97 "The topsoil variance area of the highwall reclamation is dominated by titer milkvetch..." <br />and "all grasses at the site are relatively small, but more abundant in areas of topsoil <br />application." <br />9/24/97 "Vetch continues to dominate the reclaimed facility and highwall areas." <br />It is clear that vegetation, especially in the area of no topsoil is not showing signs of successful <br />establishment of the seeded species. In addition, erosion continues to be observed, mainly in the steep <br />slope areas. The lack of substantial, self-sustaining vegetation is likely the main contributor to the <br />instability and continued erosion. <br />Therefore, due to EFMC's lack of response to the topsoil issue in general, the failure to conduct the <br />required vegetation monitoring, and the Division's evaluation of the success of establishing vegetation on <br />the topsoil substitute areas, the Division is requiring EFMC to follow through with the original plan to <br />apply 4.5 inches of topsoil to those areas which have not yet received topsoil and reseed those areas. A <br />minor revision is also required to present a detailed timetable as to when these activities will occur. The <br />Division will expect this revision to be submitted with 45 days. <br />If you have any questions about the topsoil issue or the notice of violation, please call me. <br />Sincerely, <br />G6 <br />ent Gorham <br />Environmental Protection Specialist <br />cc: Dan Hernandez, DMG <br />