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excessive exchangeable sodium levels, which could potentially lead <br />to upward migration of sodium salts which could limit vegetation <br />growth due to direct nutritional effects or indirect soil <br />structural effects. <br />The publication Reclaiming Mine Soils and Overburden in the Western <br />United States; Analytic Parameters and Procedures (1987), edited by <br />Williams and Schuman, and published by the Soil Conservation <br />Society of America contains a chapter on sodium, which includes a <br />section summarizing the research on cover soil depth requirements. <br />The generalized conclusion presented is that, if maximum grass <br />production is the reclamation goal, at least 35 inches of coversoil <br />should be replaced over a sodium affected spoil, although site <br />specific considerations including the need to buffer against mine <br />soil loss due to upward sodium migration and erosion might warrant <br />a thicker coversoil layer. Site specific pre-disturbance soil <br />characteristics are also referenced as factors which need to be <br />considered in determining the appropriate cover soil depth. It is <br />also noted that, because most of the cover depth research has <br />focused on impacts to grass production; effects of varying <br />coversoil depth over sodic material on vegetation cover, diversity, <br />and shrub and forb establishment and persistence are not well <br />documented. <br />The long term revegetation objective for the coal waste disposal <br />area is to establish a sagebrush/grass vegetation community. <br />Review of soil type descriptions for soils in the affected area <br />which supported sagebrush/grass prior to disturbance indicates that <br />in general, the soils associated with this vegetation type are good <br />quality loams and silt loams at least 30 inches thick. <br />The enclosed journal article Trace Element and Salt Movement in <br />Retorted Oil Shale Disposal Sites, by Stark and Redente (1986) may <br />have particular relevance to the issue in question, due to the <br />similarity of environmental conditions between the Piceance Basin <br />study site and the Deserado Mine site. The study included 1, 2, <br />and 3 foot topsoil cover depths over the relatively saline/sodic <br />shale layer. The authors reported that salt movement into the soil <br />decreased with increasing cover depth, and also reported the <br />apparent occurrence of interface effects causing the accumulation <br />of soluable salts in the cover soil immediately above the shale. <br />Soil/Refuse Sampling Recommendations <br />Apparently, none of the test plot soil sampling conducted to date <br />has been in accordance with procedures recommended by the Division, <br />with respect to sampling of incremental depths within specific test <br />plot locations. It is still not entirely clear what the procedure <br />was for the 1990 sampling. The report text states that "four <br />samples were collected on the north and south plots. Samples were <br />collected at the approximate center point of each plot and <br />composited for each lift; 12 inch, 24 inch, 36 inch, and 48 inch." <br />Was sampling limited to the 48" depth plots? Is the "12 inch lift" <br />the soil layer directly above the refuse or the layer at the <br />