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16. Some clarification and re-wording of language in the first paragraph under <br />Evaluation of Topsoil Resources, on page (d)-11 is warranted, as there seems to <br />be a mixture of outdated and current terminology used in the section. Prior to <br />mining, our understanding is that there was no dry pastureland, the land use <br />categories were irrigated pastureland, irrigated cropland (including hayland), and <br />native rangeland/wildlife habitat. Please re-word the paragraph to employ <br />current land use terminology, and ensure that the land use/soil classification <br />relationships are correctly stated. <br />17. In the 2nd paragraph on page 2.05.4(2)(d)(12), it is stated that there are 107.96 <br />acres of Map Unit 98E mapped within the permit boundary. This is not exactly <br />the case; the 107.96 acre parcel is the total acreage of the Morgan property within <br />the permit area, which is dominated by 98E soil, and is being treated in its entirety <br />as Prime Farmland. There are additional parcels of 98E soil in other locations <br />within the permit boundary. Please amend the narrative as warranted to <br />clarify this point. <br />18. The final paragraph on page (d)-12 indicates that the eastern portion of the prime <br />farmland on the Morgan property has been "backfilled with subsoil". Our <br />understanding had been that this area was backfilled and graded with typical <br />blasted spoil material, which subsequently was sampled to demonstrate <br />conformance with Prime Farmland Subsoil Suitability criteria. Please clarify <br />and amend the language as warranted. <br />19. Table 2.04.9-2, Threshold Suitability Levels for Prime Farmland Lift A and Prime <br />Farmland Lift Band Single-Lift Soils, is included on page (d)-14. Please refer to <br />Items 4 and 5 above, and revise as appropriate. In addition, we note that Boron is <br />included as a parameter in the standard regraded spoil monitoring program. <br />Please address the reason for concern with boron, and whether it has been <br />detected at elevated levels within the Bench 1 overburden zone. If elevated <br />levels of boron have been detected within the bench 1 materials that will be <br />used for subsoil substitute, boron should be included as a subsoil suitability <br />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- <br />1995 Study Area, on page (d)-16, there is reference to a 6.73 acre parcel that was <br />topsoiled to a depth of 0.8 feet, and it is stated that Map 2.05.5-4 was modified to <br />reflect the actual condition. Our review of the referenced map indicates a 6.73 <br />acre parcel within the 1995 Study Area (presumably the subject parcel), however <br />the map indicates replacement of 18" Lift A and 27" Lift B. Please clarify this <br />apparent discrepancy and amend the map and/or text as appropriate. <br />21. We have questions regarding the soil stripping process that was employed prior to <br />February 2008, in the 1999 expansion area west of 2700 road, as described at the <br />top of page (d)-17. Narrative indicates that soil was stripped in one mixed lift of <br />approximately 18" to 24", followed by stripping of suitable subsoil of an <br />7