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Mr. Dennis Conn - 2 - January 29, 1987 <br />B. Application Contents <br />1, West Elk Coal Company should include a literature review of all <br />research conducted in the Western United States, particularly <br />in Colorado, to demonstrate that successful reclamation of <br />waste piles can be achieved with less than four feet of <br />suitable non-toxic, non-combustible cover. <br />2. West Eik Coal Company should include a complete geochemical <br />analysis of pre-mine soil conditions, the lower waste pile <br />material, and roof and floor material from within the mine. <br />Other parameters to be included are soil moisture, hydraulic <br />conductivity, electrical conductivity (E.C.) sodium absorption <br />ratio (SAR), soil texture and fractions of sand, silt, and <br />clay, and major plant nutrients (nitrogen, calcium, magnesium, <br />phosphous, potassium, sulfur, iron, manganese, zinc, copper, <br />cobalt, molybdenum, and boron). <br />Analysis of the gob material in the waste pile should include a <br />fractionation or sieve test for coarse material (greater than 2 <br />mm diameter). The volume content and size range of wasta rock <br />and combustible material within the pile should be known. <br />Coarse fragments may include waste roc': anal combustible <br />(carbonaceous) material. A separate analysis should be <br />conducted for each. If any of the above information currently <br />exists in the permit application it r_an be referenced. <br />3, West Elk Coai Company should estimate the maximum rooting depth <br />(zone where 85-95% of all root biomass is found) for the <br />permanent reclamation vegetative species to be seeded on the <br />waste pile. An interpretation should he made of the soils, <br />gob, and roof and fluor analysis and plant rooting depth <br />requirements. <br />Will the plant roots be able to penetrate through the coarse <br />fragments in the gob material? Are there toxic elements or <br />nutrient imbalances present which would limit or prevent <br />re vegetation success? Are amendments or chemical fertilizers <br />needed to ensure successful re vegetation? Is there a large <br />content of combustible material within the pile? Based on the <br />geochemical analysis are there any long-range soils problems <br />that would adversely affect the permanent revegetation? What <br />is the infiltration capacity of the compacted gob material? <br />C. Test Plot Proposal <br />Currently the Division is not aware of information that <br />demonstrates that reclamation success standards can be met for the <br />Mt. Gunnison No. 1 mine lower refuse pile without application of 4 <br />feet of cover. Therefore we believe that establishment and study <br />of test plots is in order. <br />