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C-1981-008 <br />PR-06 <br />July 23, 2010 <br />Page 28 of 31 <br />78B. This item requested several clarifications to the Regraded Spoil Monitoring Program of Section <br />2.05.4(2)(d), Subsection 4.0. The subsection was amended but is not clearly worded and <br />contains inaccuracies. Please see Comment 76F above, and respond accordingly. <br />78C. This item requested amendment of Section 2.05.4(2)(d), Subsection 3.0, regarding the spoil <br />monitoring program. Subsection 3.0 was properly amended, and monitoring tables <br />2.05.4(2)(d)-•1 A and 1 B were provided as requested. The WFC response table to this item <br />referenced Subsections 6.0 and 14.0 for additional relevant amended narrative. We note a <br />typographical error in the Section 6.0 heading, which will need to be corrected; "Compatibility" <br />should be "C ompactability". <br />78D. In this item, the Division requested various revisions to the Unsuitable Spoil Mitigation Plan of <br />2.05.4(2)(d)„ Subsection 5.0. A generally acceptable plan was provided in Subsection 5.0, but <br />the wording of Item 2 of the 2nd Phase Spoil Sampling plan is not entirely clear. Please revise <br />wording to clarify that if any points of exceedance are detected by the 2nd phase sampling, <br />further sampling would be implemented as necessary to delineate the area to be remediated. <br />The size limits specified in Item 2 are acceptable and should be retained. <br />78E. In this item, the Division noted a lack of clarity regarding sampling details and <br />reporting/remediation procedures in narrative Subsection 8.1.7, and requested various clarifying <br />changes. The subsection was eliminated in the amended submittal, and the WFC response table <br />references Subsection 15.0, "Topsoil Remediation Plans", as being responsive to the concerns <br />noted. Amended Subsection 14.0 "Topsoil Suitability Criteria and Testing Plan for Reclaimed <br />Soils", is also relevant. The reorganized sections are an improvement over the previous version, <br />but we have the following requests: <br />a. Replaced soil lift thickness documentation and reporting commitments are specified in <br />Subsection 14.0 for prime farmlands, but not for areas other than prime farmlands. Please <br />provide commitment for non prime farmland area replacement soil thickness documentation <br />and reporting, comparable to that provided for prime farmlands. <br />b. Amended Subsection 15.0 is titled "Topsoil Remediation Plans", but in fact the section text <br />is the regraded spoil remediation plan, not the topsoil remediation plan. The basic sampling <br />and remediation approach is acceptable, however, the wording needs to be revised as <br />warranted to address topsoil remediation rather than spoil remediation. The reference to <br />resampling of replaced remedial soil material at an intensity of "1 hole per 5 acres" should <br />be replaced with "1 hole per 2.5 acres". Also, the plan will need to address remediation <br />that will be implemented in the event that a parameter average threshold value for a <br />particular landowner is exceeded based on sample results for a given year <br />78F. In this item, the Division requested a number of modifications to Table 2.05.4(2)(d)-1, to clarify <br />requirements and parameters for replaced soil sampling and regraded spoil sampling. In <br />response the Table was modified and split into two separate tables (d)-IA and (d)-1B, which <br />provides improved clarity and specificity. Certain further modifications to the tables (and table <br />footnotes) are requested by the Division (see Item 76A, and the amended Tables (d)-IA, (d)-1B, <br />and footnotes attached to this letter).