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Mike Boulay <br />-9- July 8, 2011 <br />on a quarterly basis for one -year prior to bond release to verify the conclusions of <br />the PHC that there are no detectable impacts to the Colorado River. <br />20. Division Response: Response accepted. <br />Rule 2.04.9 Soils Resource Information <br />21. Division Response: Response accepted. <br />22. Division Response: Response accepted. <br />23. Division Response: Response accepted. <br />24. A significant portion of the area to be affected has been previously disturbed by <br />Industrial activity, and the surface materials present in these areas are dominated <br />by industrial wastes that are essentially barren of vegetation. There are <br />generalized references to possible importation of cover material from outside the <br />permit area to serve as a growth medium within the previously disturbed areas, <br />since the surface materials within the areas of previous disturbance support little or <br />no vegetative growth. Although given the circumstances, the imported material <br />would not meet the specific regulatory definition of topsoil substitute, at least a <br />portion of the material would function as such (additional material placed over the <br />industrial waste and beneath the surface growth medium would function as subsoil, <br />or non -toxic cover). Detailed plans regarding the source, quantity, and <br />replacement thickness of proposed topsoil and non -toxic cover soil will need to be <br />provided, along with the information required by Rule 4.06.2(a), to demonstrate the <br />acceptable quality of such material as a plant growth medium. Plans for storage <br />and stabilization of such materials on the permit area will also need to be included. <br />Please address the use of imported topsoil and cover material for use in <br />reclamation of the previously disturbed industrial land use areas, pursuant to Rule <br />2.04.9(3). <br />CAM Response: Additional soil sampling is planned around site #1 in order to <br />determine if additional material can be salvaged and used for topsoil replacement. <br />After testing is complete, CAM will prepare a salvage plan for incorporation into the <br />permit. <br />Division Response: This item has not been resolved. CAM is doing additional soil <br />sampling around site #1 to determine if additional material can be salvaged and <br />used for topsoil replacement. The Division will not comment further on this issue <br />until CAM submits a topsoil salvage plan based on the new soil data. <br />CAM - Finding a source of plant growth media for the previously disturbed industrial <br />area is no longer an issue since the Division agreed to waive the revegetation <br />requirement in the industrial areas. See item 70. CAM obtained two soil <br />samples in the northwest rail corridor near soil sample TLO -1 since TLO -1 <br />