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._ -~ <br />Tom Gillis <br />-3- <br />May 4, 1990 <br />2. For the Roadside pile, I would recommend that we conditionally approve <br />the 6 inch cover depth, with the provision that currently reveaetated <br />portions of the pile meet cover and production success criteria durina_ <br />the 9th and 10th years of the bond liability period. The established <br />soil depth test plots on the Roadside pile should be maintained for <br />longer term comparisons. Based on the test plot data and field <br />observations, it would appear that a rather promising stand of shrubs <br />and grasses has been established on the 5 acre seeded area. It would <br />probably not be prudent, at this time, to completely disturh the site <br />and start over from the beginning. Need control efforts will need to be <br />initiated due to the scattered infestation of whitetop on portions of <br />the pile. Also, some interseedina of forb species may be necessary to <br />meet species diversity criteria, as forbs seeded initially were <br />unsuccessful and there is no evidence that invasion of the site by <br />desirable forbs is occurring. Small areas of the vile which were not <br />topsoiled and seeded originally should be reclaimed this fall. <br />3. The source, volume and quality of available cover soil and topsoil for <br />use on the Cameo refuse disposal areas will need to be specifically <br />addressed in the revision application, along with a clear description of <br />the sequence of cover soil and topsoil replacement and a projected <br />schedule for topsoiling and revegetation of the various refuse areas. <br />4. A comprehensive revegetation plan for the Cameo refuse areas should be <br />submitted with the TR application and should include specific provisions <br />for the enhancement of forb and shrub establishment. On level areas not <br />susceptible to erosion, strip seeding, alternate row seeding or other <br />techniques to reduce the competition from the more aggressive grass <br />species could be utilized. Use of site collected seed from the dominant <br />native forb, scarlet globemallow, as suggested in the consultant's <br />report, should be seriously considered, and a plan for collecting and <br />storing adequate quantities of the native seed should be included in the <br />TR application. <br />5. Since less than 4 feet of non-combustible soil material would be <br />replaced on the coal waste under the plan which the operator will <br />submit, it will be necessary for the operator to demonstrate that the <br />coal waste itself is non-combustible and will meet the pertinent MSHA <br />standards when the piles are constructed as proposed. <br />6. Unless specifically disallowed by MSHA combustibility criteria, a plan <br />for ripping or otherwise loosening the compacted refuse surface on the <br />Cameo disposal areas prior to soil replacement as specified by Rule <br />4.06.4(1) should be included in the revision application. <br />7. A plan for controlling the whitetop infestation should be submitted and <br />implemented as soon as possible this spring. The operator should <br />consult with the Grand Valley Pest Control District for their <br />recommendations. <br />DTM/yj b <br />cc: Jim Stevens <br />6841E <br />