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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. The <br />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 1 B; <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 m " >35 ". Please revise the Table 1 B <br />threshold criteria for rock fragment % to be consistent with the cover letter discussion. <br />The Table IB threshold criteria for rock fragment for Zone 8 has been corrected. <br />Prior to submitting responses to this review letter, please provide a copy of revised Tables 1 A <br />and IB to NRCS, with explanation andjustification 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 he 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 />to 3 parameters with PR -6. In actuality, the reduction in number of parameters was apparently <br />approved in 1999. We suggest the following replacement wording. "Prior to July 1999, <br />regraded spoil monitoring included analyses of 7 parameters. The parameter list was reduced at <br />that time to 3 parameters (boron, pH, and EC), based on information obtained over the course of <br />the initial monitoring program. The current requirements for regraded spoil and replaced topsoil <br />monitoring (updated for PR -6 in 2010) are presented on Tables 2.05.4(2)(d) -lA and IB. The <br />sampling grid is oriented north- south/east -west, to reflect the current mining pattern. Sample <br />intensity is 1 sample location per 2.5 acres in areas where the surface spoil functions as a subsoil <br />substitute, 1 sample location per 5 acres in all other areas." <br />The final two paragraphs of the subsection should be deleted. <br />The reference in the first paragraph of this subsection to the "the top four feet' has been <br />removed. The final two paragraphs of subsection 4.0 of Section 2.05.4(2)(d) have been <br />replaced with the DBMS language from above. <br />77. Resolved. <br />