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show "good" ratings for pH, with most samples in the neutral range, and no indications of <br />excessive alkalinity. <br />The referenced difficulty of incorporating P fertilizer in the same paragraph, could be <br />addressed by disking or other standard tillage on drill seeded areas, and by "extensive <br />roughening" operations on steep slope locations. <br />Data generally appear to show that "A" horizon soils are suitable, with adequate fertility <br />levels, while "B" and "C" horizon materials and other potential growth materials are <br />generally suitable for plant growth media, but typically exhibit lower levels of fertility. It <br />would appear that replaced topsoil will generally consist of "A" or mixed "A" and "B" <br />materials, and would be expected to exhibit adequate fertility for native species without <br />amendment. Surface materials associated with regraded East Mine bench and loadout area <br />locations, would likely include a mix of upper soil horizons, subsoils, and underlying <br />materials, and would likely exhibit lower levels of fertility than replaced topsoils, due to <br />dilution and inverse replacement. For the reasons indicated in the amended text, application <br />of nitrogen fertilizer at the time of initial seeding is not recommended. Application of <br />phosphorus may be warranted on non-topsoiled areas however, and due to the fact that <br />phosphorus fertilizer needs to be incorporated into the soil, it should be added, if warranted, <br />prior to seedbed preparation operations. <br />Please amend the "Fertilization Methods" narrative on page 74a, to specify soil testing <br />(from representative composite sampling of upper 12 inches of growth medium) within <br />logical reclamation parcels for all final reclamation areas that are not topsoiled. <br />Sampling should include the parameters specified in second paragraph under (2)(e)(v), <br />on amended page 74a, with the addition of testing for organic matter and <br />texture/particle size analysis. Standard analytical procedures should be specified [e.g. <br />Saturated Paste Extract for pH, EC, and (Na, Ca, Mg., for SAR calculation), AB- <br />DTPA extract method for remaining chemical parameters, hydrometer method for <br />particle size analysis (report as % sand/silt/clay and texture)] . Narrative should <br />specify that P fertilizer would be applied prior to seedbed preparation based on the <br />results of the soil test analyses, and that areas of low nitrogen fertility would be visually <br />assessed and N fertilizer added in a subsequent growing season, if vegetative growth <br />indicates that such amendment is warranted. <br />6. Review of the reclamation plan indicates that topsoil will (or has previously been) replaced <br />on all final reclamation areas at the West Mine. Average replacement depths of 8-9 inches <br />are listed for the waste disposal area, and 24 inches for certain other locations, but no <br />narrative, table, or map that presents a comprehensive listing of average topsoil replacement <br />thickness for each logical reclamation parcel (based on salvaged volume and final <br />reclamation acreage) could be located. <br />Please provide a narrative, table, or map that specifies average replacement thickness <br />for each logical reclamation parcel to be topsoiled. <br />3