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h. The revegetation plan is rather general with respect to seeding <br /> techniques, seedbed preparation, and mulching treatments. Since <br /> such procedures would be expected to vary significantly given the <br /> wide range of growth media and slope gradients and could have a <br /> considerable bearing on the success of revegetation efforts, <br /> specific seeding and planting plans should be provided for the <br /> various reclamation sites. Categories would include steep cut and <br /> fill slopes associated with the roads and mine benches, topsoiled <br /> refuse slopes, backfilled portals, the reclaimed facilities area, <br /> etc. Particular emphasis should be placed on slope gradient as it <br /> relates to equipment accessibility and erosion potential . The <br /> bonding estimate may need to be refined based on the more detailed <br /> revegetation plan. <br /> i . Stipulation No. 6 of the Sutey property Permit Revision requires the <br /> oermittee to sample vegetation on the refuse disposal facility <br /> biannually, beginning with the third year of growth. There is no <br /> evidence that this has been done. Please clarify which sections of <br /> the pile were seeded when, and what has been or will be done to <br /> comply with this stipulation. In connection with this issue, it is <br /> requested that Mid-Continent address measures which will be taken to <br /> prevent grazing on the refuse piles in order to promote vegetation <br /> establishment. <br /> j . Also related to reclamation of the Sutey refuse disposal facility. <br /> we believe it to be appropriate to verify the projections upon which <br /> the variance from the four foot non-toxic cover requirement was <br /> made. Vegetation surveys performed by the Division in 1989 on the <br /> old refuse area indicate poor vegetation establishment in many <br /> areas. The original study upon which the variance was based should <br /> be submitted for inclusion in the application. The Division further <br /> requests that Mid-Continent submit a plan for collecting <br /> representative samples of coal waste material and cover material on <br /> the Sutey refuse pile. Full suite soil and refuse analyses will <br /> need to be submitted to the Division as part of the midterm <br /> response. The Division will utilize this data, along with <br /> vegetation data to be collected this summer, and any additional <br /> information submitted by Mid-Continent, to complete our evaluation <br /> of the cover depth variance. Cover soil samples should be taken by <br /> six inch depth increments. The top 12-18 inches of the refuse <br /> should be sampled as a unit. Soil samples should be taken from a <br /> minimum of three sites widely spaced within reclaimed portions of <br /> the pile. Refuse samples should be taken from the same locations, <br /> as well as one additional sample comoosited from numerous subsamoles <br /> distributed across the non-topsoiled portions of the Sutey pile. A <br /> list of required topsoil and refuse parameters is enclosed as <br /> Exhibit 2. This information should be provided by September 1 . 1991 . <br /> k. The final reclamation plan for the preparation plant yard includes <br /> the use of 64,000 cubic yards of coal processing waste in <br /> backfilling. A commitment to apply all provisions of Rule 4.10 <br /> should be included in this plan, and the reclamation cost estimate <br /> will need to be amended as appropriate. If refuse material will not <br /> be used, the source of any alternative backfill material will need <br /> to be specifically identified. <br /> -9- <br />