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C- 1981 -008 PR -06 <br />PAR — Supplemental <br />06- Apr -2010 <br />Page 6 of 7 <br />and lift B, Prime Farmland Bench 1 Suitable Subsoil, Prime Farmland surface spoil <br />(beneath lift B), Non -Prime Farmland Single Lift Topsoil, Non -Prime Farmland Bench 1 <br />Suitable Subsoil/Surface Spoil. For reasons detailed previously, selenium should be <br />deleted from the list of parameters. Boron should be retained for Bench 1 Suitable <br />Subsoil and Surface Spoil (and should be included on an amended Table 2.05.4(2)(d)). <br />79. Footnote 5 to Table 2.05.4(2) (d) -1 contradicts the table entry for coarse fraction. <br />Footnote 5 indicates that Prime Farmland coarse fraction would not have greater than <br />10% cobbles and larger fragments, and total coarse fraction not be greater than 15 %. <br />This is the criteria listed in the Table for Prime Farmland Lift A; however the Prime <br />Farmland Lift B criteria in the table is less restrictive (> 35% one location and > 25% <br />average), and does not specify a "cobbles and boulders" limit. Were the criteria for Lift <br />B developed with MRCS concurrence? Please address the apparent contradiction <br />between the table column for Lift B criteria and the footnote and revise the footnote for <br />clarity. <br />80. The Division has reconsidered the procedure for follow -up soil sampling and remediation <br />for Bench 1 material applied to prime farmland re- establishment as described on page <br />2.05.4(2) (d) -38. The provision that allows for establishment of follow -up sampling <br />points 150' out from a parameter threshold exceedance should be revised. Please revise <br />to specify that, if the initial sample grid detects a parameter exceedance, follow -up <br />sampling would be undertaken to define the boundaries of the exceedance area, and <br />suspect material would be replaced with a sufficient thickness of suitable material to <br />ensure that any remaining unsuitable material is at least 8 feet below the soil surface. <br />Please revise the narrative section as appropriate. <br />In addition, comparison of Subsoil Sample #32 1:1 and saturated paste extraction EC <br />values indicates that one of the values may be in error (based on the ratio of the two <br />values compared to the ratio of the other paired values). Please resample the upper two <br />feet of the subsoil at site #32 and run another saturated paste extract EC. If the re- <br />sampled value exceeds 6.0 mmhos, please perform follow -up sampling to determine the <br />extent of the exceedance area. <br />81. The Division has identified several other details that will clarify the topsoil replacement <br />sampling plan. Please include the following provisions to the topsoil replacement plan: <br />• Measure and report the replaced thickness for both the subsoil and topsoil lifts. <br />Depth measurements should be taken at the same locations as the sample sites. <br />• Sampling and depth measurements will need to be completed on an annual basis and <br />the results submitted with the Annual Reclamation Report. <br />82. A new paragraph of text has been added to page 2.04.3 -9 (redline version). The last <br />sentence of the paragraph refers to Map 2.04.10 -1 - Pre -Mine Vegetation. We believe the <br />correct reference should be to Map 2.04.10 —Vegetation Baseline. Also, the first <br />sentence of the following paragraph refers to Table 2.04.3 -1 — Acreages by Land Use, <br />