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C- 1981 -008 <br />PR -06 AR #5 <br />80A. Previously resolved. <br />August 25, 2010 <br />Page 24 of 26 <br />80B. In this item, the Division requested commitment regarding follow -up sampling and remediation <br />associated with Bench 1 Sample Site 932, to be performed prior to topsoil replacement. Two <br />previous sample analyses had indicated EC levels slightly above 7.0 mmhos /cm, in exceedance <br />of the 6.0 threshold criteria for Bench 1 subsoil substitute material. In response, WFC stated that <br />the location was sampled once again, in July 2010, with an EC result of 3.98 mmhos /cm, which <br />is below the applicable threshold, and which WFC concludes is sufficient to demonstrate that no <br />further testing or remediation is warranted for the location. Amended narrative in Subsection <br />16.0 describes the Sample Site #32 EC results, and references the July 2010 testing by Walsh <br />Environmental (analytical results provided in amended Attachment 2.05.4(2)(d) -1). The <br />Division is not convinced that two samples showing EC levels above 7.0, and I sample with EC <br />result of 3.98, for the same sample location, would be adequate to demonstrate that material in <br />the vicinity of Site #32 is suitable for subsoil substitute. <br />However, the Sample Site 432 location appears to be within Soil Replacement Zone 3, and as <br />such would be required to be covered by a minimum 48" topsoil thickness (at least 15" mixed lift <br />topsoil and at least 33" Lift B topsoil). If this is the case, the Division would concur that <br />sampling has demonstrated acceptable salinity levels in the vicinity of Sample Site #32, since all <br />sample results are below the 8.0 suspect level applicable for surface spoil. Please confirm that <br />Site #32 is located within Replacement Zone 3, and if so, please amend the narrative in Section <br />16.0 to clarify that this is the case, and that the Bench 1 material in the location would be <br />covered by at least 48" of mixed lift and Lift B topsoil. Conversely, if Sample Site #32 is within <br />Replacement Zone 2 (such that the Bench 1 material at the location would function as subsoil <br />substitute), please revise Subsection 16.0 narrative to state that the remediation plan as addressed <br />in Subsection 15.0 would be implemented at the site prior to replacement of the mixed lift <br />topsoil. <br />80C. The issues raised by this item have been addressed within Items 78D and 78E, above. As a <br />result, the Division considers this item to have been resolved. Item Resolved <br />80D. The Division had several editorial comments regarding Section 2.05.4(2)(d), Subsection 15.0. A <br />couple typographic errors were corrected; however the sentence that immediately follows <br />mitigation plan item #4 still does not make sense as written. Please revise the sentence "WFC <br />will maintain..." as warranted. <br />81. -83. Previously resolved. <br />84. Probable Hydrologic Consequences text has been updated regarding former and predicted spoil <br />springs, and the text now matches the spoil springs as depicted on Map 2.04.7 -1A. Item Resolved <br />85. The Division requested that several items be added to the list for inclusion in the Annual <br />Reclamation Report, in Subsection 10.0 of Section 2.05.4(2)(e). The list was updated as <br />requested. Item Resolved <br />86. In this Item the Division had requested WFC to update the Weed and Pest Control Plan in <br />Section 2.05.4(2)(c), Subsection 9.0, to comply with requirements of Rule 4.15.1(5), to address <br />all species listed as noxious by Montrose County and other applicable weed control districts, <br />