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to the permit requiring that this material be analyzed in accordance with Rule <br />4.06.2(4)(a)(i). <br />12. Please see response to item #8. <br />13. Please see response to item #8. <br />14. (NEVIS In light of the shortage of remaining topsoil which has resulted, in part, from <br />replacement of excess amounts of topsoil in some azeas and, in light of the apparent <br />continued variability in replacement depths evidenced by recent DMG inspections, we <br />believe Seneca should implement additional measures to account for volumes of <br />redistributed topsoil. The Division will consider approving a reduction of the depth of <br />topsoil required for redistribution. However, Seneca will be required to add several <br />commitments to the permit to ensure that the topsoil remains in place after redistribution. <br />In order to verify replacement depths, we suggest the following plan: <br />For each of the reclamation blocks indicated on Exhibit 9-3 C, thickness of replaced <br />topsoil should be verified by SCC prior to seeding operations. Replaced thicknesses <br />should be measured in each block systematically on a 550-foot triangular grid pattern. <br />This is roughly equivalent to one sample per three acres. If replaced depths aze no more <br />than two inches less than the required depth or, no more than four inches greater than the <br />required depth, seeding operations would proceed. If a variance beyond these limits <br />from the required replacement depth is measured, three secondary samples would be <br />taken at 120 degree increments around the first sample, 275 feet away (i.e., half the <br />distance to the sample nearest the first point, for three of the six nearest samples). If <br />these samples indicate variances, another two samples would be taken 275 feet from the <br />secondary sampling point on either side of the secondary sample where the variance was <br />found. Any variations in replaced topsoil depths outside the acceptable limits would <br />need to be corrected prior to seeding the reclaimed areas. The monitoring data and results <br />should be submitted to the Division prior to seeding. Please see attached diagram for <br />clarification. <br />15. (NEVIS [n order to enstue that replaced topsoil is not lost to erosion and remains in place, <br />Seneca should implement the following measures: <br />a. propose a contour furrow plan on steep slopes noting furrow height, spacing and <br />slope, <br />b. conducting seeding operations parallel to slope contours on all areas except those <br />that are steep enough to present a safety concern to equipment operators, <br />c. implementing rill and gully repair measures described on page 13-30 of the permit <br />immediately if any gullies are observed which expose regraded spoil beneath <br />replaced topsoil. <br />