_GENERAL DOCUMENTS - C1981017 (252)

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Ms. Diane Delaney - 4 - February 23, 1993 Topsoil There is an apparent shortage of topsoil to properly perform reclamation on most of the disturbed areas. Past experience has shown, however, that even a thin cover of topsoil provides a good seed bed and nutrient source to properly establish vegetative cover and increase productivity over adjacent non-topsoiled areas . MCR has proposed that borrow areas be identified to supplement topsoil reserves on hand. Please submit a map identifying these areas for approval as soon as possible. The proposed plan calls for placement of at least 6 inches of topsoil over all disturbed areas except for the Sutey pile, which will be held to previously approved standards . This proposal is acceptable as long as the regraded material below the topsoil is capable of supporting vegetative growth. If this regraded material or fill is demonstrated to be unsuitable, additional suitable fill or a thicker cover of topsoil will be required. The Division agrees that certain areas, such as the overland conveyor route, should possess suitable growth medium characteristics after regrading without requiring additional topsoil . This can be addressed on a case by case basis as reclamation proceeds . The current plan does not indicate whether topsoil will be added to the roads. The Division believes it is appropriate to do so, especially for reclaimed road surfaces . Other Issues This concludes the discussion of the requested changes to the current Coal Basin reclamation plan addressed in the recent MCR letter and/or discussed in our meeting. A few outstanding issues remain. The current seed mix needs to be updated to incorporate the positive results from the test plots . Specifically, species that demonstrated good establishment and/or production on the test plots should either be included in the seed mix if they weren' t previously, or their ratios increased if they were. I will propose seed mixes for use at the various sites for your review and approval prior to going to the Board with the revised plan. Unless something different is proposed, we will proceed with incorporating the substance of Technical Revisions 19 and 21 into the permit application. Following this the revisions will be withdrawn, for administrative purposes . This action will be dated after the revised reclamation plan is approved by the Board.