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Mr. Allen Weaver, EFMC 2 C-82-055 <br />A brief description of the six basic issues follows. <br />1. Surface soil conditions of areas being reclaimed. <br />a. The floor of the yard area is composed of highly compacted material that <br />appeared to be unsuitable as a growth medium for revegetation. Division personnel stated <br />that the highly compacted surface material of the yard area should be loosened by <br />mechanical means (Rule 4.06.4(1)) prior to topsoil redistribution (Rule 4.06.4(2)). EFMC <br />may attempt to demonstrate that the existing soil medium is the best available in the permit <br />area to support revegetation as per Rule 4.06.2(4); however, the Division does not believe <br />such demonstrations may be appropriate until all stockpiled topsoil material has been <br />utilized. Please note that topsoil and topsoil substitutes approved under Rule 4.06.2(4) must <br />satisfy plant nutrient requirements as per Rule 4.06.5. <br />b. The backfilled highwalls at the northwest end of the yard area have been surfaced <br />with extremely coarse textured and dark colored material. Topsoil replacement has not <br />occurred over much of this area. Rills and gullies have developed. EFMC personnel stated <br />that the backfilled slopes would be "chiseled" on a line perpendicular to the slope to remove <br />existing gullies and to help slow the speed of runoff thereby reducing future erosion and <br />increasing soil moisture for revegetation. Division personnel stated the existing surface <br />soil may be unsuitable as a substitute for topsoil due to its {ow water holding capacity <br />resulting from its coarse texture. The potential for unsuitably dry soil is compounded by the <br />slopes south-facing aspect and dark coloration. <br />2. Topsoil material availability. <br />a. In an effort to determine weather all topsoil salvaged and stored at Topsoil <br />Stockpile 3 had been utilized, Division inspectors and EFMC personnel dug several holes <br />in the stockpile area. Two holes were dug near the apex of the former stockpile, one hole <br />9 inches deep, the other hole 15 inches deep. Division inspectors did not encounter any <br />change in color, texture or organic content. Several holes were dug at the perimeter of the <br />former stockpile; changes in color and texture were encountered irrunediately in the <br />perimeter holes. A large mound of topsoil material was left to provide support for the <br />utility pole planted within the stockpile. The Division believes that significant quantities of <br />topsoil remain at Topsoil Stockpile 3 and that the available topsoil is superior to the existing <br />surface soils for the area described in paragraph 16 of this letter. All topsoil stockpiled <br />should be utilized. Please refer to Rules 4.06.2(4)(a), 4.06.2(4)(a)(i), 4.06.4, and 4.06.5. <br />b. Additional topsoil material may be required to provide adequate support for <br />revegetation success for the areas described above in paragraph la and lb. The Division <br />encourages EFMC to seek additional sources of topsoil material. <br />