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11 <br />1981-038 TR-48 <br />2°d Adequacy Review <br />09-Jun-2008 <br />specify extensive roughening seedbed preparation on all areas to be broadcast or hydro-seeded, <br />and provide additional detail regarding the extensive roughening procedure(s) to be employed <br />(e.g. track-hoe gouging or contour dozer ripping specifications). <br />The narrative was amended in BRL's adequacy response letter dated 30-Apr-2008. <br />5) Soil descriptions, suitability summary information, and test results in the Volume 9 Soils Appendix <br />for the mine area and Exhibit 7 for the loadout area do not appear to confirm the statement in the <br />initial paragraph of amended page 74a, that soil resources "have high pH levels which will result <br />in poor availability ofphosphorus ". In contrast, the data generally show "good" ratings for pH, <br />with most samples in the neutral range, and no indications of excessive alkalinity. <br />The referenced difficulty of incorporating P fertilizer in the same paragraph, could be addressed <br />by disking or other standard tillage on drill seeded areas, and by "extensive roughening" <br />operations on steep slope locations. <br />Data generally appear to show that "A " horizon soils are suitable, with adequate fertility levels, <br />while "B" and "C" horizon materials and other potential growth materials are generally suitable <br />for plant growth media, but typically exhibit lower levels of fertility. It would appear that <br />replaced topsoil will generally consist of "A " or mixed "A " and "B " materials, and would be <br />expected to exhibit adequate fertilityfor native species without amendment. Surface materials <br />associated with regraded East Mine bench and loadout area locations, would likely include a mix <br />of upper soil horizons, subsoils, and underlying materials, and would likely exhibit lower levels of <br />fertility than replaced topsoils, due to dilution and inverse replacement. For the reasons <br />indicated in the amended text, application of nitrogen fertilizer at the time of initial seeding is not <br />recommended. Application ofphosphorus may be warranted on non-topsoiled areas however, <br />and due to the fact that phosphorus fertilizer needs to be incorporated into the soil, it should be <br />added, if warranted, prior to seedbed preparation operations. <br />Please amend the "Fertilization Methods " narrative on page 74a, to speck soil testing (from <br />representative composite sampling of upper 12 inches ofgrowth medium) within logical <br />reclamation parcels for all final reclamation areas that are not topsoiled. Sampling should <br />include the parameters specified in second paragraph under (2)(e)(v), on amended page 74a, with <br />the addition of testing for organic matter and texture/particle size analysis. Standard analytical <br />procedures should be specified [e.g. Saturated Paste Extract for pH, EC, and (Na, Ca, Mg., for <br />SAR calculation), AB-DTPA extract method for remaining chemical parameters, hydrometer <br />method for particle size analysis (report as % sand/silt/clay and texture)]. Narrative should <br />sped that P fertilizer would be applied prior to seedbed preparation based on the results of the <br />soil test analyses, and that areas of low nitrogen fertility would be visually assessed and N <br />fertilizer added in a subsequent growing season, if vegetative growth indicates that such <br />amendment is warranted. <br />The "Fertilization Methods" narrative was amended in BRL's adequacy response dated 30-Apr- <br />2008. <br />6) Review of the reclamation plan indicates that topsoil will (or has previously been) replaced on all <br />final reclamation areas at the West Mine. Average replacement depths of 8-9 inches are listed for <br />the waste disposal area, and 24 inches for certain other locations, but no narrative, table, or map <br />that presents a comprehensive listing of average topsoil replacement thickness for each logical <br />2