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Mining and reclamation activities are continuing to the west of 2700 Road. The following <br />findings are for the lands west of 2700 Road as evaluated for PR -6. <br />A. Salvage <br />Topsoil salvage thicknesses and stripping procedures are described in Subsection 16 of <br />Section 2.04.9 of the permit. The topsoil resource is removed and segregated in <br />advance of mining operations. The extent of topsoil removal is limited to <br />approximately two pit widths in advance of the active pit highwall, an area that will <br />allow subsequent removal of overburden and coal from the pit being mined. <br />Subsections 16.6 and 16.7 discuss stripping of frozen and saturated topsoil. <br />For those areas not determined to be prime farmland, all available topsoil is stripped in <br />a single "mixed" lift using a bulldozer or other suitable equipment. Beneath the <br />topsoil is a layer of unconsolidated overburden ( "Bench 1" material) of varying <br />thickness. This material is excavated separately, generally using the mine shovel, and <br />placed in the uppermost level of regraded spoil behind the pit as "Bench 1 Surface <br />Spoil ". Details are provided in Subsection 16.4 of Section 2.04.9 of the permit. <br />The Division has determined that the Bench 1 overburden material can be used for, or <br />as a supplement to topsoil within specific locations of the original NH -2 permit block. <br />The resulting soil is equal to or better than the available topsoil. This determination is <br />based on physical and chemical analyses approved by the Division (4.06.2(4)(a)). <br />In addition, the Division has determined that the Bench 1 overburden material can be <br />used as a subsoil substitute on a 20.05 acre portion of the Morgan property <br />immediately to the west of 2700 Road (Soil Replacement Zones 1 and 2 on Maps <br />2.05.4 -4 and 2.05.4 -6). Sufficient subsoil had not been salvaged prior to the positive <br />prime farmland determination for the Morgan property, and is not available in advance <br />of the mine pit, to provide an adequate prime farmland rooting medium over the entire <br />property. Based on chemical and physical information provided by the operator <br />pursuant to 4.06.2(4)(a), and included in the permit, the Bench 1 overburden material <br />is the best material available in the permit area to support revegetation. In <br />Replacement Zones 1 and 2, a 21 inch thickness of mixed A and B lift soil will be <br />replaced over a 33 inch thickness of the Bench 1 substitute subsoil. <br />In February 2008, the NRCS determined that the 107.96 acres of Morgan property, <br />located immediately west of 2700 Road and south of BB Road, was prime farmland. <br />Topsoil had been already salvaged from approximately 56 of the acres, at an average <br />thickness of 22 inches and stockpiled at the eastern end of the Morgan property. <br />Mixed topsoil had also been distributed across an area of 5 acres, adjacent to 2700 <br />Road. Once the prime farmland status of the Morgan property was known, topsoil <br />stripping methods were immediately revised to salvage the entire available thickness <br />of potential root zone material in two lifts according to the requirements of Rule <br />4.25.3. "Lift A" material, which is dark brown in color, is salvaged first. It is easily <br />differentiated from "Lift B" material, below, which is a light pink color. Both soil lifts <br />., <br />