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C- 1981 -008 <br />PR -06 AR##5 <br />76B. -C. See Comment 76A, above. <br />August 25, 2010 <br />Page 22 of 26 <br />76D. This item concerned portions of Table I and 1B footnote material which the Division felt were <br />no longer applicable. In addition, the item requested additional detail regarding methodology for <br />rock fragment sampling. Finally, in response to Table modifications recommended by the <br />Division, the operator presented reasons to delete the rock fragment sampling requirement for <br />certain replacement zone topsoil lifts. <br />a. Amended footnotes are presented following Table 1B. The footnote narrative is then <br />reiterated in somewhat different and outdated language in four narrative paragraphs on the <br />following page, which appear to be relic from the previous version of the text. The outdated <br />paragraphs should be deleted. <br />b. The rock fragment sampling description was amended as requested in the amended footnotes. <br />Item Resolved <br />c. WFC presented justification in the 8/10/2010 response cover letter, to eliminate the rock <br />fragment sampling requirement for Morgan property Lift A and Mixed Lift topsoils (Zones 1, <br />2, 3, and 4); Benson -West, Lloyd, and WFC Non -Prime Mixed Lift Topsoil in Zone 7; and <br />the top two feet of WFC prime farmland in Zone 8. Justification for elimination of the rock <br />fragment sampling for the designated zones, is that the specified lifts in these zones involved <br />soils that exhibited low rock content in the native soil horizons, and the replaced soils would <br />be subject to rock picking operations as a component of soil preparation prior to seeding. <br />The Division concurs with the arguments presented. One discrepancy was noted between the <br />cover letter item response discussion and the rock content criteria presented on Table 1B; <br />specific criteria are listed for the upper 2 feet of Zone 8, and no specific criterion was listed <br />for mixed lift topsoil below 2 feet in Zone 8. Based on the discussion presented in the cover <br />letter, the Zone 8 upper 2 feet Rock Fragment criteria should be listed as "N /A ", and Zone 8 <br />Rock Fragment criteria below 2 feet should be listed as ">35 ". Please revise the Table 1B <br />threshold criteria for rock fragment % to be consistent with the cover letter discussion. <br />Prior to submitting responses to this review letter, please provide a copy of revised Tables lA <br />and 1B to MRCS, with explanation and justification for the amended criteria, for their review and <br />comment, and include the NRCS review comments in the response submittal. <br />76F. In this item, the Division had requested amendments to Subsection 4.0 of Section 2.05.4(2)(d), to <br />clarify confusing narrative. The Division further requested that details regarding sample <br />increments, intensities, and threshold levels be addressed in amended tables (d) -lA and (d) -1B, <br />with appropriate references in the text. The narrative was amended, but certain sections of the <br />text are still misleading or confusing. <br />The sentence at the end of the first paragraph indicates that the sampling program "will ensure <br />that the top four feet of regarded spoil is non -toxic and chemically /physically suitable to enhance <br />plant growth ". In actuality, the thickness of the surface spoil layer that would be sampled varies <br />from 2 to 4 feet, depending on location and thickness of overlying topsoil lifts. Language should <br />simply state that the sampling program will ensure that the surface spoil zone is non -toxic and <br />chemically /physically suitable to support plant growth. <br />The third paragraph of the subsection (immediately following the first reference to the tables) <br />would seem to imply that the required spoil sample parameters were reduced from 7 parameters <br />