GENERAL31326

• Permit No: C1980005
• IBM Index Class Name: General Documents
• Doc Date: 6/6/1997
• Doc Name: PROPOSED DECISION AND FINDINGS OF COMPLIANCE FOR RN3
• Permit Index Doc Type: FINDINGS
• Media Type: D
• Archive: No

N. Topsoil
Information regazding topsoil may be found in Volume 7, Tab 9 of the original permit
application package.
Information in the original findings document for Seneca II Mine (August 10, 1981)
identified two concerns; heavy clay concentration in certain soil types and, limited soil
salvaging in steep slope areas. To mitigate the heavy clay concentration, Seneca Coal
Company proposed stripping topsoil in single lifts to mix different soil orders and to
dilute the heary clay concentration. This salvaged topsoil is either taken directly to
regraded spoils or to a topsoil stockpile. Seneca Coal Company proposes to continue this
practice except, when feasible, topsoil will be salvaged in two lifs and redistributed
directly on regraded areas. This practice promotes the natural regeneration of existing
species.
Steep slopes (40-60%) are encountered within the Seneca II Mine permit azea. A
stipulation requiring approval of a varrr._ice from topsoil salvaging on those areas was
placed on the original permit approval. A request for variance from topsoil salvaging of
some steep slope areas as identified on Exhibit 9-3, was submitted as part of the Wolf
Creek Permit Revision. This variance request for the Wolf Creek Permit Revision Area
was approved by the Division on September 25, 1984.
Seneca Coal Company was originally (1981) approved to return approximately 1.4 feet
(15-18 inches) of highly suitable topsoil to regraded areas. As addressed in the Wolf
Creek Permit Revision and approved by the Division, the depth of topsoil replacement
was reduced to approximately 12.2 inches. To verify compliance of this topsoil
replacement depth, Seneca Coal Company committed to a final topsoil balance survey for
the duration of mining. To verify compliance, Seneca Coal Company has expanded the
quality control program as addressed on pages 9-40 and 9-41 of the revised permit
document with a commitment to annual topsoil balance surveys.
As part of the 1994 Midterm Review, Seneca incorporated a current topsoil balance into
the permit. All of the existing topsoil piles were resurveyed in the Spring of 1996.
Approximately 379.7 acre-feet of soil was stockpiled at the Seneca II Mine as of May 15,
1996. The disturbance area requiring soil replacement totals 607.4 acres. It is estimated
that 0.5 feet of suitable soil is availably .o be replaced on the disturbed area. The soil
replacement thickness for the remaining permit term is approved to be 12.2 inches.
Seneca has failed to provide any additional information to substantiate the claim of
suitability of 0.5 feet of topsoil replacement. Due to the lack of supporting
documentation on 0.5 feet of topsoil replacement, the following stipulation is warranted;
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