_INSPECTION - C1981008 (45) - Laserfiche WebLink

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technical standard for the Morgan property, which is 1.84 tons/acre. • Topsoil salvaged as "Lift A" by WFC includes the A-Horizon and additional thickness to the depth at which the color changes from a deep, reddish-brown to a lighter, pinkish-tan tone. The Lift A soil horizons that have been salvaged in advance of the south end of the pit were over 3' thick. The depth WFC salvaged exceeds what the permit requires. The permit says that WFC will "strip Lift A to color change or 24 inches whichever is greater". Mr. Boyd felt that salvaging the full depth of Lift A is the preferred method to maximize the soil nutrients. Therefore, the permit will need to be revised to state that the total depth of Lift A will be stripped and salvaged. • Mr. Boyd suggested that planting a "green manure" crop is recommended as a way to re- introduce organic content to the soil once topsoil has been redistributed, and that this would likely be considered a normal husbandry practice, as it is employed in the region to rejuvenate cropland soils that have not been mined. Mr. Boyd offered to write a letter regarding the subject of "green manure". • The thicker "Lift B" salvage operation removes the entire thickness of pinkish soil, stopping when the color changes to buff/gray at the top of the "Bench 1" material. The lift B material appeared to be at least 6 feet thick where salvaged in advance of the south end of the pit. In the permit WFC recognizes that the Lift B is variable ranging from 20-60" deep depending on the location. The permit states that an average of 36.7 inches will be salvaged based on the variable depths seen in the field. As with Lift A, WFC must commit to stripping and salvaging the entire depth of Lift B soil. • The depth of Bench 1 material is variable. Visually there are three distinct zones, a sandstone derived buff colored unconsolidated upper material, a zone of apparent salt accumulation along the interface and the thinly bedded shales below. The buff colored sandy material comprises the upper 1/3 or less of the Bench 1 material, with thinly bedded shale strata comprising the lower portion of Bench 1. A very light colored zone of apparent elevated salt concentration from 2 to 5 feet thick was evident along the interface between the upper unconsolidated material and the lower thinly bedded shales. The thickness of the Bench 1 material (and the various component zones)decreases from south to north across the permit area. The upper zone appears to be most favorable for plant growth. • Mr. Gubka drove us to the top of the Lift B topsoil stockpile on the Morgan property. Two access ramps have been constructed onto the pile; one on the east and one on the west. The pile is built as mine haul trucks transport Lift B topsoil salvaged ahead of the mining operation. Topsoil is end-dumped on the pile, sometimes enlarging the footprint, and other times increasing the height of the pile. • Ms. JoEllen Turner recently alleged that WFC was mixing Lift B topsoil with Bench 1 material and hauling the combined soil to the Lift B stockpile. We examined the stockpile for evidence of contamination with Bench 1 material, and observed only incidental amounts of clay and sand. We did not observe any component that would be detrimental to reclamation using Lift B stockpiled soil. • The Division has requested WFC to evaluate the volumes of Lift A and Lift B topsoil stockpiled to date and anticipated for salvage for the remainder of the Morgan. These volumes must be compared with the redistribution plan(s) in the currently approved version of the permit. To improve the likelihood of successful revegetation efforts, it would be desirable to extend A-Lift and/or B-Lift replacement further to the east (assuming required replacement thicknesses are maintained in the west). Mr. Gubka stated that WFC had surveyed the volumes of the Lift A and Lift B stockpiles, but that numbers were "too close to call" as far as adjusting any replacement thicknesses. There is to be no "live-haul" of prime farmland topsoil or additional replacement of stockpiled prime farmland topsoil until the updated topsoil volumes are submitted and approved by the Division. Backfill & Grading • The Division has recently received complaints from Ms. Turner regarding WFC's placement of New Horizon Mine C-1981-008 3-May-2010 -3-