2011-01-13_PERMIT FILE - C1981014A

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Below this level, physical and chemical soil characteristics are similar in many respects to those of in-place overburden or coal refuse materials, In addition, there is no significant difference in material characteristics within the 0 to 16 inch interval. In conjunction with PR-O1, EFCI noted that topsoil availability is limited due to historic site disturbance where topsoil was not recovered. Given this limitation and a desire to use the available soil resources to best advantage, EFCI completed physical and chemical analyses to evaluate the suitability of refuse as a revegetation medium. The results of the analyses. as summarized in Exhibit 19. Comparison of Refuse and Soil Suitabilities, indicate that further testing to verify the suitability of refuse materials may be justified. Future topsoil recovery will involve removing all available topsoil to the extent operationally feasible utilizing either tractor-scrapers or a tracked- dozer in combination with wheel-loaders and trucks. Control of topsoil recovery depth is currently the responsibility of both the Surface Foreman and the equipment operators. Depth of cut is determined by both visual observation, color or other identifiable soil characteristics, and contact with rocky deposits. This approach has worked well to date, with operator conservatism typically resulting in recovery depths slightly greater than specified. Recovery of an average of 6.8 feet of soil materials from remaining refuse stockpile expansion areas will result in approximately 80,200 cubic yards of soil which will be stockpiled in topsoil pile M-4, or directly replaced on regraded areas. Topsoil will generally be recovered during late summer or early fall and will either be place in temporary stockpiles for future use or, to the extent possible, directly replaced on regraded areas. Direct replacement, or live topsoil handling, will be utilized whenever possible in order to 2.05.3-58 Revised 5/13/04 Permit Renewal RN-04