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placement of thin layers of soil on coal refuse in these conditions is very <br /> dangerous. Past experience has shown that the construction equipment <br /> will rut and track up the coal refuse with the soil, thus contaminating it. <br /> This problem could be costly as could the additional mobilization costs <br /> associated with doing earthwork at this time of year. <br /> Work in wet or snow conditions is contrary to regulatory requirements for <br /> protection of topsoil during redistribution. <br /> 4.06 TOPSOIL <br /> 4.06.4 Redistribution <br /> (2) Topsoil and other materials shall be redistributed in a manner that: <br /> (b) Prevents excess compaction and contamination of topsoil and spoil or <br /> subsoil. <br /> (d) Protects the topsoil from wind and water erosion during redistribution <br /> and before and after it is seeded and planted. <br /> The Division previously discouraged Mid-Continent's handling of topsoil under <br /> snow conditions. A Division Memo dated June 30, 1987, concerning work at the <br /> Sutey site said, in part: <br /> Considering the stability problems experienced with the existing topsoil <br /> stockpile at Sutey, the operator should make the commitment that no <br /> topsoil will be salvaged or stockpiled if there is snow on the ground. <br /> The established practice for use of equipment and topsoiling on the Sutey pile is <br /> that such work is done in the summer months, when ground conditions were dry. <br /> The approved permit, Vol. 1, Chapter II, page 41, provides: <br /> Before topsoiling occurs the area will be inspected each spring and any <br /> rills and gullies noted. As the area dries out, mechanical equipment will <br /> be used to reshape the area. <br /> After topsoiling, inspections to identify erosion problems will be conducted <br /> once per month from May through July. Inspection will also be made after <br /> any significant rainfall event. If any (problems) are noted, temporary <br /> control will be established....When the refuse pile dries out (generally July <br /> and August), mechanical methods wil be used to remove or fill the rills and <br /> gullies. <br /> IV. Unnecessary Expenditures and Increased Costs. <br /> In addition to the other problems which may occur, the timing of the project <br /> increases the cost of reclamation. <br /> DMG Bid. <br /> MCR Objections/DMG Bid <br /> Page 12 <br />