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Mowry - TR 5 Somerset - 2 - November 5, 1987 1. The addition of new Table 1 as referenced in the last paragraph on page 1 pertains to some additional soil sampling performed in 1966 and 1987. Based on these soil samples, the operator specifies that 6 inches of topsoil is needed to cover the coal and gob material in the central yard and east bench; whereas, the ". generally less than 6 inches ." of coal material can be scraped from the west bench exposing some subsoil material. The approved plan does not reference the importation of topsoil but from a review of the latest soil inventory, it is obvious topsoil importation is required. It is unclear, however, if 6 inches is an adequate depth to provide for adequate nutrients and moisture to the plants considering the medium below this imported topsoil is useless. Also, the information of Table 1 for the west bench at cross section B-B' depicts a coal depth of "1+ foot" which exceeds the ". generally less than 6 inches ." depth referenced above. Considerations should be given to increasing the importation depth to at least 12 inches for the central yard and east bench. Also, better documentation is necessary to support the operator's claim pertaining to the depth of coal on the west bench. We could probably stipulate the minimum 12 inch topsoil depth for the central yard and east bench, but we'll need some assurances about the depth of coal on the west bench unless we impose the minimum 12 inch topsoil depth for this area as well. 2. While not a change, the plan calls for surface ripping to a depth of at least 12 inches. Assuming we concur to the requested 6 inch depth, we cannot allow ripping to 12 inches as this will cause a mixing of the coal or gob with the imported topsoil resulting in a degradation of the topsoil. Specifying a new topsoil depth of a minimum 12 inches would resolve this concern. 3. While not a change, the plan still calls for the broadcasting of 30 pounds per acre of phosphorous fertilizer, While the original plan revolved around dealing with the existing material, the new plan discusses topsoil importation. Rather than an arbitrary 30 pounds per acre fertilizer rate, the operation should commit to analyzing the topsoil for nitrogen, phosphorous, potassium, pH, electrical conductivity, and sodium absorption ratio and adding fertilizer or amendments as required. 4. The seed mixture has been drastically reduced in terms of number of species and seeding rate. The rationale provided for this dramatic decrease is "A limited number of species is used to prevent competition thus enhancing revegetation success potential." While the approved seed mixture of 13 grasses, 8 fortis and 10 shrubs