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a. WFC correctly claims there were no suitable subsoil analyses reported in the 2009 ARR. Upon review <br />of the ARR, the Division noted that the required subsoil analyses had not been provided for areas <br />where suitable subsoil had been replaced in 2008/2009, subsequent to the 2008 monitoring. The <br />Division notified WFC of the missing data by phone, and requested that the data be obtained and <br />provided as soon as possible. The Division felt this was appropriate since topsoil had not yet been <br />replaced over the Bench 1 material. WFC hired Lambert and Associates to collect the data and the <br />report was submitted on May 20, 2010. <br />b. The Division did ask WFC to resample site SS-32 in earlier correspondence to confirm the accuracy of <br />previously reported EC levels, and to assess the need for more intensive sampling and possible <br />remedial measures at the site. I'm not sure why WFC is bringing this issue up. It is not referenced, nor <br />a part of the NOV. <br />c. It's unclear what WFC is considering substitute spoil replacement sites. WFC refers to Bench 1 <br />Material as substitute soil in several places in the permit. WFC is required to sample Bench 1 material, <br />referred to as suitable subsoil, on the Morgan Prime Farm Land Property. WFC contracted with <br />Lambert to conduct the analysis. The Division believes the plan approved in TR-57 on page <br />20.5.4(2)(d)-34 and 35 applies. WFC commits to sample all subsoil for pH, EC, field texture, saturation <br />%, SAR, exchangeable sodium %, calcium carbonate %, selenium, particle size and percent coarse <br />fraction. <br />I think it is appropriate for you to consider WFC's conclusion and decide whether or not the Lambert Report <br />data is a valid part of the NOV. The Division thought all sampling would be conducted for materials that were <br />replaced within a given year. However, the permit does not specify that and we are revising the schedule for <br />sampling with Permit Revision No. 6 currently under review. The critical timing, as stated above, is that the <br />sampling must be conducted on suitable subsoils prior to topsoil replacement.