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So, the cited Attachment (d)-1 discussion indicates that stripping and replacement of Bench <br />1 overburden material would be (and has been) a standard operating practice, whereas the <br />permit narrative on page (d)-6 indicates that Bench 1 overburden is typically hauled or <br />blasted into the adjacent pit void, and that stripping and surface replacement of the Bench 1 <br />overburden (prior to soil replacement), is done only where "special handling" is necessitated <br />based on identification of unsuitable material on the surface of the replaced spoils. <br />Please address this discrepancy; and amend the permit text or Attachment (d)-1 <br />description as warranted to be consistent and to accurately describe the overburden <br />handling operation as practiced in the past and proposed for current and future <br />operations. <br />16. Some clarification and re-wording of language in the first paragraph under Evaluation of <br />Topsoil Resources, on page (d)-11 is warranted, as there seems to be a mixture of outdated <br />and current terminology used in the section. Prior to mining, our understanding is that there <br />was no dry pastureland, the land use categories were irrigated pastureland, irrigated cropland <br />(including hayland), and native rangeland/wildlife habitat. Please re-word the paragraph <br />to employ current land use terminology, and ensure that the land use/soil classification <br />relationships are correctly stated. <br />17. In the 2"d paragraph on page 2.05.4(2)(d)(12), it is stated that there are 107.96 acres of Map <br />Unit 98E mapped within the permit boundary. This is not exactly the case; the 107.96 acre <br />parcel is the total acreage of the Morgan property within the permit area, which is dominated <br />by 98E soil, and is being treated in its entirety as Prime Farmland. There are additional <br />parcels of 98E soil in other locations within the permit boundary. Please amend the <br />narrative as warranted to clarify this point. <br />18. The final paragraph on page (d)-12 indicates that the eastern portion of the prime farmland <br />on the Morgan property has been "backfilled with subsoil". Our understanding had been <br />that this area was backfilled and graded with typical blasted spoil material, which <br />subsequently was sampled to demonstrate conformance with Prime Farmland Subsoil <br />Suitability criteria. Please clarify and amend the language as warranted. <br />19. Table 2.04.9-2, Threshold Suitability Levels for Prime Farmland Lift A and Prime Farmland <br />Lift B and Single-Lift Soils, is included on page (d)-14. Please refer to Items 4 and 5 above, <br />and revise as appropriate. In addition, we note that Boron is included as a parameter in the <br />standard regraded spoil monitoring program. Please address the reason for concern with <br />boron, and whether it has been detected at elevated levels within the Bench 1 <br />overburden zone. If elevated levels of boron have been detected within the bench 1 <br />materials that will be used for subsoil substitute, boron should be included as a subsoil <br />suitability parameter, and the table will need to be properly amended. <br />20. In the final two sentences of the second paragraph under Topsoil Salvage Depths-1995 Study <br />Area, on page (d)-16, there is reference to a 6.73 acre parcel that was topsoiled to a depth of <br />0.8 feet, and it is stated that Map 2.05.5-4 was modified to reflect the actual condition. Our <br />6 <br />