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2.05.4(2)(e) has a date stamp of 24aug06 in the file name. <br />For the 2009 Topsoil Sample No. TS-94, 98,99,100,101, and 103, these sites <br />were tested post TR-57 approval and were lacking the PAP test of Calcium <br />Carbonate (%), Selenium (ppm) and course fragment (%). It is true that WFC did <br />not follow the new topsoil testing parameters as approved with TR-57 and <br />misreported the results in the 2009 ARR. It should be pointed out that TR-57 <br />was approved in 2009 and these were some of the first samples that were taken <br />under the new test parameters. We were new at this level of testing. I would like <br />to add that all during that time and even into today, the whole permitting issues <br />has been in a steady state of change and missed communication between Tom <br />Fry, my Engineering Assistance who collects the soil samples and myself <br />occurred. <br />WFC understands the issue and will retest all ten sites for Calcium Carbonate, <br />Selenium and Course Fragment. <br />Item 2, page 3 of the CV-2010-003 document states "For Bench 1 suitable <br />subsoil on the Lloyd property, WFC failed to report results for Saturation <br />Percentage; Sodium Absorption Ratio; Calcium Carbonate (%); Selenium (ppm) <br />and coarse fragments (%). <br />WFC Response: I refer the reader to Greg Lewicki July 6, 2010 letter and <br />attachments that are enclosed in this letter. WFC and Greg Lewicki feels that <br />the sampling of Bench 1 on the Lloyd property falls under the spoil test <br />parameters. No violation should be placed on this item. <br />Item 3, page 3 of the CV-2010-003 document states "For Bench 1 suitable <br />subsoil on the Morgan property, WFC failed to separately analyze and tabulate <br />results for Gravel, Cobble, Stone and Boulder (as necessary to document total <br />coarse fragment percentage). In addition, textural classification of the Bench 1 <br />suitable subsoil was reported using the engineering-base Unified Soil <br />Classification rather than the appropriate USDA agronomic-based system of <br />classification." <br />WFC Response: There was no suitable subsoil analysis reported in the 2009 <br />ARR. WFC believes that DRMS is referring to the 20May10 test data report <br />generated by Lambert and Associates for sites located on the Morgan Property. <br />WFC believes Dan Mathews requested WFC to resample test site SS-32 because <br />of an elevated EC value and a difference in Lab analysis procedure. WFC <br />2-14