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• For progressive disturbance associated with the permanent coal refuse <br />stockpile this commitment to timely reclamation translates into regrading, <br />topsoil replacement, and revegetation of completed stockpile areas as soon <br />as possible after refuse placement activities achieve the design <br />elevation. At current and projected future rates of coal refuse <br />placement, EFCI generally completes a refuse stockpile area ranging in <br />size from 2 to 4 acres during each calendar year. In order to achieve <br />optimal reclamation success, seeding of reclaimed areas during mid to late <br />fall is the determining factor in scheduling and sequencing all other <br />preceding reclamation activities. By seeding in the fall, seed materials <br />are allowed to winter over in order to take advantage of elevated soil <br />moisture levels resulting from winter snow pack and runoff in the spring. <br />With seeding scheduled for mid to late fall, topsoil removal and <br />replacement will normally occur during late summer or early fall. <br />Scheduling of topsoil removal and replacement activities during this time <br />interval offer several significant benefits; <br />• <br />o Favorable ground conditions allow for efficient equipment <br />operations with minimal potential for rutting, erosion, or <br />adverse impacts to the surface water hydrologic system <br />o Seedheads for most native and introduced species mature during <br />mid to late summer. Where live topsoil handling may be <br />utilized, early fall topsoil removal results in increased <br />recovery of viable seed and biomass <br />Placement of topsoil and subsequent seeding will result in some <br />unavoidable compaction. By completing these activities in the fall, <br />freeze and thaw cycles which occur during late fall, winter and spring <br />will tend to alleviate the effects of compaction through frost heaving and <br />other natural mechanisms. <br />EFCI has committed to maintain a minimum 15 foot buffer zone between spoil <br />placement and undisturbed or newly topsoiled areas. Topsoil replacement <br />and revegetation, which will occur each fall, will extend to within 15 <br />feet of the active coal refuse placement crest. Given that coal refuse <br />2.05.4-3 <br />