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New Horizon Mine, C- 1981 -008 January 31, 2011 <br />Ten Day Notice #X11 - 140 - 182 -002 Page 2 <br />appeal response pending the outcome of the Division's review and proposed decision on PR6. The <br />appeal of the DFD finding remains open The most recent TDN #X11 - 140 - 182 -002, revisits many of the <br />same allegations addressed in TDN #X10 - 140 - 182 -003. <br />Background information regarding the Morgan property prime farmland designation is summarized in <br />the Division's findings in Section II. E1 on page 16. Further background is discussed in the Division's <br />response to OSM's Ten -Day Notice X10 - 140 - 182 -003 dated April 23, 2010. <br />As of February 2008, when the positive prime farmland determination was made, 51.6 acres of the 108 <br />acres of Morgan property had already been disturbed. Topsoil salvaging methods for the 51.6 <br />disturbed acres were not subject to the topsoil salvaging requirements for prime farmlands. WFC was, <br />however, operating in accordance with their approved permit at the time. Some topsoil had been <br />replaced on approximately 5.8 acres at the eastern end of the Morgan property in 2006. No final <br />reclamation had yet occurred when the prime farmland designation was made. In February 2008, WFC <br />immediately modified their topsoil salvaging techniques to salvage the full depth of "Lift A" and "Lift B" <br />topsoil for future disturbances on the Morgan property, and to replace soil and subsoil that is suitable to <br />restore prime farmland characteristics on all 108 acres of the Morgan Property. Technical Revision No. <br />57 (TR57) addressed the immediate soil management for the prime farmlands. This was followed -up <br />with PR6 where WFC committed to revegetate to prime farmland standards. The entire Morgan <br />property will be reclaimed to cropland — irrigated alfalfa hay and must equal or exceed the revegetation <br />success standard for three years. <br />A synopsis of past and proposed reclamation activity on the Morgan Property is provided below. <br />• Permit Map 2.04.9 -2 depicts the mine's topsoil and backfilling status as it existed in February <br />2008 when the NRCS determined that Darvey -Barx soils (Unit 98E on Map 2.04.9 -1 Baseline Soil <br />Survey) were prime farmland soil. On the Morgan property, topsoil had been already salvaged <br />from 51.6 acres. <br />• For topsoil redistribution purposes, PR6 divided the Morgan property into Zones 1, 2, 3 and 4, as <br />depicted on Map 2.05.4 -6. An excerpt from this map is attached. <br />• As of February 2008, Zones 1 and 2 were already backfilled with overburden, and topped with <br />Bench 1 material in preparation for subsequent topsoil redistribution. WFC was directed to <br />evaluate the placed Bench 1 material to determine if it was suitable to be used as subsoil. <br />(Results of the 2008 suitability study conducted by Walsh Environmental are reported in <br />Attachment 2.05.4(2)(d) -1 of the permit). Zones 1 and 2, comprising 20 acres, are the only areas <br />of the Morgan property where Bench 1 material is to function as subsoil substitute. <br />• The Zone 1 area SE of Mixed pile #5 was topsoiled in the fall of 2006 to a depth of approximately <br />14 ". Topsoil was dozer - pushed across the remainder of Zone 1 in late 2009. Final thickness, <br />land leveling, etc. has not been done on any of the Zone 1 topsoil. <br />• No topsoil has been distributed over Zone 2, much of which is currently covered by topsoil <br />stockpiles. <br />• In February 2008, the eastern side of Zone 3 had been partially backfilled with overburden, <br />while the active pit occupied the western half. <br />• Currently, the active pit is located in Zone 4, and much of Zone 3 has been backfilled with <br />overburden. Since February 2008, all topsoil salvaged from the Morgan property has been <br />