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TDN Response Page 10 <br />New Horizon Mine <br />April 23, 2010 <br />Lift B soil is subsequently salvaged in a similar manner, although the material is not stripped as far <br />westward as the Lift A topsoil. This process results in a stair -step appearance, wherein each lift creates <br />its own bench with an outer berm for safety and/or sediment control. Thicknesses of the B Lift are <br />quite variable, and have been observed to range from less than 5 feet to as much as 10 feet on the <br />Morgan property. The entire thickness of Lift B soil is salvaged, loaded into haul trucks, and carried to <br />the Lift B soil stockpile, also located to the east of (behind) the active pit. <br />Lift B soil is underlain by "Bench 1" material which is typically highly weathered sandstone and/or <br />shale and very friable. The Bench 1 material is very thick on the Morgan property, and seems to be in <br />the neighborhood of 20 to 30 feet. This material can generally be excavated by mining equipment and <br />does not require blasting. Bench 1 material is not stockpiled, and is instead hauled by truck to the back <br />side of the open cut and dumped to form a thick layer (approximately 20 to 30 feet) atop the rockier <br />overburden that has been blasted and pushed or hauled into place. <br />Reclamation of the trailing edge of the pit has not quite (as of April 2010) reached the western limit of <br />the 51.6 Morgan acres that were disturbed prior to February 2008. The upper 26 inches of Bench 1 <br />material currently being placed as backfill will be serving as "suitable subsoil" (in lieu of Lift B soil) <br />and will be covered with a minimum of 22 inches of Mixed A and B topsoil that was stockpiled prior <br />to February 2008. The Division estimates that within the next few months, topsoil redistribution.on the <br />Morgan property will be modified to incorporate replacement of individual Lifts A and B. <br />Two December 2009 aerial photos are attached to this letter to illustrate the topsoil salvage and <br />replacement operations as they relate to the active pit. The first photo provides an overview of the <br />entire cut; the second photo is a close -up view of the same photo, focusing on the prime farmland <br />details of the Morgan property. <br />Soil Resources Summary <br />As stated under the Prime Farmlands Section, in early 2008 when the Division was notified that Prime <br />Farmlands may be present within the PR -5 expansion area, we acted swiftly. Revised topsoil <br />management practices were implemented on the ground in February 2008 and TR -57 incorporated <br />those revisions into the permit. For all disturbances after February 2008 when the Division determined <br />that Prime Farmlands soils may be present, WFC committed to salvaging and replacing an average of <br />16 inches of Lift A, 36 inches of Lift B and returning a minimum of 3 feet of Bench 1 Material to the <br />Morgan property. (p. 2.04.9 -25 and 26). WFC will continue to sample the suitability of replaced <br />subsoil and topsoil using the NRCS suitability criteria for Prime Farmlands. The Division's decisions <br />were not arbitrary, capricious, or an abuse of discretion. When the Division determined that Prime <br />Farmlands may have been present it took immediate and appropriate action to ensure their <br />preservation. <br />LAND USE AND REVEGETATION <br />Land uses and vegetation classifications are closely related at the New Horizon Mine. The <br />predominant land use and vegetation type at the mine is irrigated pasture.. On the Morgan property, the <br />