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In February 2008, the NRCS determined that the 107.96 acres of Morgan property, <br />located immediately west of 2700 Road and south of BB Road, was prime farmland. <br />Topsoil had been already salvaged from approximately 56 of the acres, at an average <br />thickness of 22 inches and stockpiled at the eastern end of the Morgan property. <br />Mixed topsoil had also been distributed across an area of 5 acres, adjacent to 2700 <br />Road. Once the prime farmland status of the Morgan property was known, topsoil <br />stripping methods were immediately revised to salvage the entire available thickness <br />of potential root zone material in two lifts according to the requirements of Rule <br />4.25.3. "Lift A" material, which is dark brown in color, is salvaged first. It is easily <br />differentiated from "Lift B" material, below, which is a light pink color. Both soil <br />lifts are salvaged and handled separately, as described in Subsection 16.4 of Section <br />2.04.9 of the permit. A low berm is constructed along the leading edge of the <br />salvaged Lift A to prevent potential erosion of the resource. <br />A second area, on the WFC property in the northwestern corner of the permit, was <br />also designated prime farmland in 2008. An area of 2.83 acres within the prime <br />farmland had been previously disturbed for the construction of Pond 013. Topsoil <br />was salvaged in a mixed lift, and stockpiled in two locations nearby. There are no <br />additional disturbances planned for this area. <br />B. Storage <br />Topsoil salvaged from non-prime farmland areas is generally direct hauled by truck <br />and dumped in windrows on the regraded surface spoil on the trailing side of the <br />active pit. This topsoil is not typically stockpiled, although one stockpile is proposed <br />for the final phases of mining, as illustrated on Map 2.05.4-7. Subsection 8.0 of <br />Section 2.05.4(2)(d) provides details regarding topsoil storage. <br />On the Morgan prime farmland property, numerous topsoil stockpiles have been <br />developed and more are proposed, as shown on Map 2.05.4-6 and described in <br />Subsection 16.4 of Section 2.04.9 and Subsection 8.1 of Section 2.05.4(2)(d) of the <br />Permit. "Mixed" topsoil was stockpiled at the eastern end of the property, prior to <br />the prime farmland determination. As of February 2008, and for the remainder of <br />mining operations, Lift A and Lift B topsoil materials are stockpiled separately. The <br />stockpiles will likely remain until mining and backfilling operations have been <br />completed. The stockpiles were hydro-seeded and hydro-mulched to protect against <br />wind erosion and to prevent adverse impacts to air quality. The stockpiles have been <br />constructed on a level, stable surface, and will remain undisturbed until redistributed <br />in accordance with the approved reclamation plan. <br />Topsoil storage for the small prime farmland acreage on WFC property is described <br />in Subsection 8.2 of Section 2.05.4(2)(d). <br />C. Redistribution <br />45