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For the eastern portion of the Morgan property, the average mixed lift stripping thickness was <br />22 inches. The mixed lift is confirmed by the data in the 1998/1999 study, which shows that Lift <br />A on the east portion of the Morgan property is only 17 inches thick. In addition, the bench 1 <br />material was stripped and placed as suitable subsoil to a depth of approximately 34 inches. <br />The areas backflled as of February 2008 are shown on Map 2.04.9 -2. The Morgan property <br />south of BB Road and west of 2700 Road is now considered prime farmland and has therefore <br />resulted in stricter topsoil stripping and replacement procedures for this area. <br />8.6 Stripping after February 2008 - Prime Farmland Soils <br />The prime farmland designation for the 98A and the 98E soils was identified by the NRCS in <br />February of 2008. This resulted in numerous consultations with the DRMS and the NRCS about <br />how to immediately modify the topsoil handling plan to ensure that all prime farmland soils for <br />reclaimed prime farmlands were handled properly. This was done in TR 57 which was <br />aooroved in 2008. At that time the initial far eastern portion of the Morgan orooertv was already <br />covered with subsoil using the Bench 1 subsoil material (min 26 inches). This area was <br />approximately 51.6 acres. WFC immediately embarked on a testing program to demonstrate <br />that this subsoil met all the criteria for Lift B as stipulated by the NRCS for prime farmland soil, <br />as shown in Table 2.05.4(2)(d) -1. All this subsoil and the topsoil (Lift A) placed above it came <br />from the Morgan property. The total thickness of the Lift A and Lift B placed on this area <br />exceeds the 48 inches required by the NRCS and approved in TR -57 in 2008. For this reason <br />WFC believes it has done eveWhing possible to ensure that the Morgan topsoil and subsoil has <br />been replaced adequately for those areas that were subsoiled prior to February 2008. <br />Also, all topsoil and subsoil materials stripped from the Morgan orooertv after February 2008 <br />are placed back on the Morgan property according to the following sequence, which is a <br />commitment on the part of WFC: <br />Too Zone - 12" to 24" of Lift A (as salvaged from the Morgan property) <br />Middle zone - 30" to 40" of Lift B (as salvaged from the Morgan orooertv) <br />Bottom zone - 3 feet of Bench 1 material. <br />(Revise October 2009) 2.05.4(2)(d) -27 <br />