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C-1981-008 <br />PR-06 <br />July 23, 2010 <br />Page 27 of 31 <br />In recent discussions, WFC representatives have made the argument that rock fragment content <br />sampling may not be warranted for Lift A topsoil and mixed topsoil on the Morgan property <br />(Zones 1,2,3 &4), for the Morgan property Lift B topsoil (Zones 3&4), for the Lloyd and WFC <br />non-prime mixed topsoil (Zone 7), for the WFC prime farmland mixed topsoil upper 2 feet <br />(Zone 8), or the WFC prime farmland mixed topsoil below 2 feet (Zone 8). Based on the fact <br />that Lift A and mixed lift topsoils would be anticipated to have a low rock content (based on the <br />characteristics of in place soil horizons), and further based on the fact that replaced topsoils <br />would be subject to rock picking operations, the Division is willing to consider modification of <br />Tables 2.05.4(2)(d)-1 A and 1 B to eliminate the requirement for rock fragment sampling on <br />mixed lift and Lift A topsoil. Due to the potential for incorporation of rock fragments from <br />sandstone lenses during Lift B salvage operations on the Morgan prime farmland, and further <br />due to the fact that rock picking operations are not applied to Lift B soils following replacement, <br />the Division believes the requirement should remain for rock fragment sampling on the Morgan <br />prime farmland Lift B and the WFC prime farmland mixed topsoil (below 2 feet). <br />Written justification for any modifications to the rock fragment sampling specifications listed <br />on Tables 2.05.4(2)(d)-IA and 1B will need to be provided in the responses to this letter, and <br />the justification will need to be supported by written concurrence from the NRCS. <br />76F. The narrative in Subsection 4.0 pertaining to "Regraded Spoil Monitoring Program", is <br />awkwardly written, making it difficult for the reader to separate procedures that were employed <br />in the past, from those that are proposed with PR-6. Please amend the narrative for clarity. We <br />suggest that the narrative refer to the referenced tables, with regard to current sample <br />increments, intensities, and threshold levels, and that the narrative description of such details, be <br />deleted. In the paragraph that immediately precedes Table 2.05.4(2)(d)-lA, please delete the <br />erroneous statement indicating that a 600' x 600' grid corresponds to 1 hole per 5 acres. <br />77. Resolved. <br />78A. This item requested narrative clarification regarding the circumstances that resulted in use of <br />Bench 1 spoil as subsoil substitute material on the eastern portion of the Morgan prime <br />farmland. The item further requested an explanation of the testing conducted and the standards <br />established to demonstrate suitability of the material, along with a map delineating the area <br />where the Bench 1 substitute material was sampled in 2008. The narrative information is <br />provided in Section 2.05.4(2)(d), Subsections 9 and 14, with a more detailed description in <br />Attachment 2.05.4(2)(d)-1. Map Figure 1 provided in the cited Attachment, along with <br />amended permit Maps 2.05.4-4 and 2.05.4-6, further clarify the status and plans for use of <br />Bench 1 spoil as subsoil substitute, and the extent of testing that was conducted in 2008. In <br />summary, Bench 1 surface spoil was tested for substitute subsoil suitability on the eastern half <br />of Morgan property soil replacement Zone 3, all of Zone 2, and the portion of Zone 1 that had <br />not been topsoiled as of February 2008. Approximately 7.6 acres of Zone 1, along the extreme <br />eastern side of the Morgan property had been topsoiled (approximately 17" of mixed topsoil) <br />prior to initiation of the 2008 Bench 1 subsoil substitute sampling program. See Map 2.05.4-6 <br />for the soil replacement zone delineations on the Morgan property. Item Resolved.