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Submitted by: J. Mersch Ward <br />July 13, 2003 <br />Description of Overburden, Deposit and underlyinQ stratum <br />¶ 1: Soil thickness is reported to be approximately 6 inches yet when farmed and plowed <br />it is likely that the plow is cutting to a depth often to twelve inches. This depth would <br />more likely reflect the recoverable soil depth. This needs to be reviewed to insure <br />maximum soil recovery. Soil replacement during reclamation needs to take into account <br />compaction after placement. Six inches replaced is not six inches after settling and <br />compaction. <br />Primary and Secondary Commodities <br />¶ 1: Overburden and soil should not be sold. If the reclamation plan suggests that there is <br />excess material then the plan is flawed. <br />Exhibit E -Reclamation Plan <br />Tonsoil seereeation. Preservation and Renlacement <br />Topsoil berms not vegetated need to be covered to avoid wind and water erosion. Also <br />topsoil berms, which cannot be immediately revegetated need to be covered until the next <br />growing season to avoid wind and water erosion. <br />Tonsoil Replacement <br />Six inches of topsoil for re-spreading should be six inches or more after natural settling <br />and compacfion. No topsoil or overburden should be shipped off the property in sales or <br />for any other reasons. <br />Reve eg tation <br />It is not understood why it is necessary to have a permit in hand in order to determine <br />what will grow best under the proposed reclamation plan. If the plan is changed, a <br />second seed mix could be formulated. Further to this, it is felt that one seed mix will not <br />fit all conditions at the conclusion of mining. For instance, the pit floor may not be the <br />same as the pit slopes and they in turn may not be the same as the top edges of the pit. A <br />seeding mix and plan needs to be in place that is acceptable to the State prior to the <br />issuance of any permit. <br />Maintenance <br />Fertilizer use should be required over all parts of the reclaimed and undisturbed azeas to <br />insure maximum root growth during the two-yeaz reclamation period and for any yeaz <br />after where the reclamation continues to be unsatisfactory. If cropland is the end use, <br />watering systems need to be in place to insure sustaining growth. If a natural environment <br />