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highwal/ or upper three feet of final graded spoil will be scarified prior to being <br />covered with topsoil. <br />There is no specific sampling area delineated on Map 6-6A for the South Extension, <br />corresponding to the sampling area delineated on Map 6-6 for the original permit <br />area. However, because the Lennox seam overlies the Wadge in significant portions <br />of the Wadge mine block in the South Extension, and because of the acid forming <br />potential of the Wolt Creek overburden, it seems clear that the spoil monitoring plan <br />is to be applied throughout both the Wadge and Wolf Creek mining blocks le.g. all <br />mined areas) of the South Extension Area. The Tab 21 sampling and mitigation plan <br />is referenced. <br />Four spoil samples were taken within a small rough graded area at the south end of <br />the Wolf Creek block in December 2004. However, no samples were taken in the <br />20+ acres of final graded spoil in the Wadge mine area, in the northern portion of <br />the South Extension Area. <br />a) Pleese explain why no sampling was conducted in the final graded areas of the <br />South Extension Wadge Area. <br />bl Please address measures that are being taken to ensure that current and future <br />spoil sampling, evaluation, and remediation if necessary, will be implemented prior <br />to topsoiling, in accordance with the approved permit, throughout the South <br />Extension Area. <br />11. Rule 4.06.4(2)(a) requires that topsoil be replaced in a manner that "achieves an <br />approximate uniform, stable thickness consistent with approved postmining land <br />uses...and requirements of the vegetation proposed to be established". Narrative on <br />page 32 of Permit Tab 21 states that topsoil replacement thickness will be <br />documented and recorded for each reclamation block. Within the original permit <br />area boundary, the permit specifies a mean replacement depth of 1.3 feet. Topsoil <br />replacement thickness is to be sampled with an intensity of 1 hole per 5 acres, and <br />the results are to be submitted in the annual reclamation report. <br />This requirement has been somewhat inconsistently addressed in recent years. In <br />2002, there were no samples reported for the 20 acre parcel topsoiled. In 2003, <br />information was limited to a narrative summary indicating that mean replacement <br />depth was 1.5 feet, over 61 acres topsoiled, based on 10 samples. A similar <br />summary was provided in the 2004 report, indicating "an average replacement <br />depth of 26 inches over 28 samples" in the "A" Pit area. In addition, the 2004 <br />report included the results of 25 randomly distributed auger samples taken from <br />locations in the "D" Pit and "A" Pit that had been topsoiled in 2003, and analyzed <br />for standard soil fertility and quality parameters. The analyses document that the <br />replaced soils are a high quality clay loam growth medium, with no inhibitory <br />characteristics. One soil pit was excavated in the "A" Pit area and a soil profile <br />description provided, along with complete analyses for two depth increments (total <br />thickness of 22 inches). Sample sites are plotted on a map, and the report indicates <br />that sample depths ranged from 18 to 24 inches. Soil depths for individual sample <br />locations are not presented. <br />To allow for meaningful assessment of replaced topsoil thickness, individual sample <br />hole depths need to be reported, with the sample locations plotted on an appropriate <br />map. Such information would document the variation among sample locations, <br />allowing for a more quantitative estimate of the mean, and the mapping would <br />