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-3- be distinct from one another. )f I understand the reclamation plan correctly the topsoil to be used for reclamation will be borrowed from the lawrence Huntington property which is in the valley bottom upland from the refuse disposal area. This area was left out or not clearly or adequately described in the baseline data. It is not clear from reading the permit text and reviewing the soils map whether topsoil was salvaged and stockpiled and if so how much. At any rate, not enough was stockpiled to complete reclamation and additional undisturbed material will have to be borrowed. It is possible the stockpiled material may not be topsoil at all, but a subsoil or topsoil substitute. Therefore, the operator will need to do the following: 1. Conduct an analysis of this soil material to determine its suitability as a growth medium and/or topsoil substitute. This will involve sampling of [he material for laboratory analysis including the following parameters: pH saturation percentage % organic matter selenium and boron (if pH> 8.5) textural analysis lead sodium adsorption ratio cadmium acid-based potential mercury molybdenum The operator should sample this material for these constituents this year. If the material turris out to be suitable, the fertility parameters can be checked when reclamation is performed. If it turns out that this material is not suitable, another borrow area will need to be identified. The Division will also need better data on the amount of material available. Another area that requires some clarification is exactly how many acres will be reclaimed. While conducting the review I have come across at least four conflicting figures of 6.25 acres. R ,.. ,nd 10.25 acres and 8.36 acres. The actual figure should be flushed out, a map provided which clearly shows the area to be reclaimed, and all references in the text should be consistent with this figure. These numbers are found m both the old and new text. It appears the operator intends to use material from the sediment pond as a topsoil substitute. Based on the data presented in the application, all of the settling pond material (both sediment and embankments) could be deemed unsuitable based on pH alone, (if 5 or less). )f the soils in indeed acidic, it could be used as fill material so long as it is buried two feet deep. This material should be tested when the suitability test on the "topsoil borrow area" material is performed. After the results of this test are in, a determination of suitability as topsoil material can be made.