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apparent that DRMS accepted an average salvage depth extending more than 7 inches into the C <br />horizon overburden, even though what limited confirmation sample data that is available <br />indicates the C horizon is not suitable for prime farmland reclamation. <br />In addition to the above estimates for soil available for salvage, the permit includes (later in the <br />text) a summary of the volume of materials anticipated to be redistributed during reclamation, <br />considering the volume that has been salvaged/stockpiled through Fall 2010 and the small <br />acreage remaining on the Morgan property which had not yet been disturbed/salvaged [section <br />2.05.4(2) (d)]. <br />According to the permit (page 2.05.4 (2) (d) -31), there is 177,930 cubic yards of Lift A available <br />for redistribution. Based on the discrepancy for what was reported as being available at the time <br />of salvage (125,646 cubic yards, calculated from Table 4) and what was reported as having been <br />stockpiled (177,930 cubic yards), OSM concludes that 52,284 cubic yards of lift A (stockpiled) <br />consists of additional B horizon material not accounted for in Table 4. The permit also states <br />that there are 393,629 cubic yards of Lift B material for use in reclaiming Zones 3 and 4. <br />According to OSM's calculations using data taken from Table 4 in Attachment A, only 286,934 <br />cubic yards of B materials (37.9 inches) are available for salvage. And of this 286,934 cubic <br />yards, 52,284 cubic yards is being salvaged with the A lift, therefore there is only 234,650 cubic <br />yards of B Lift material available for redistribution. The difference between OSM's Lift B <br />calculated redistribution volume (234,650 cubic yards) and permit reported redistribution volume <br />(393,629 cubic yards) is 158,979 cubic yards. Based on this difference it appears WFC has <br />indicated in the permit that they have an additional 21 inches of lift B material available for <br />redistribution. <br />These latter numbers describing the volume of topdressing materials (topsoil/subsoil) available <br />for reclamation are significantly greater than those included within Table 4 which describes what <br />suitable materials (A and B horizon soils) are available for salvage and use in reclamation. More <br />specifically, from this discrepancy it appears that the operator has salvaged or is planning to <br />salvage 158,979 cubic yards of lift B materials more than what was identified in Table 4 as being <br />the limits of suitable materials (A and B horizon soils) being available for reclamation. Based on <br />the data from the Order 1 Soil Survey, this would strongly imply that the permittee's subsoil <br />salvage operations on the Morgan's post -2008 acreage have extended far deeper into the C <br />horizon than what was recommended in the Order 1 Soil Survey and even far beyond the depths <br />included within Table 4 of the permit, which had already shown extending at least 8 inches <br />further into the C horizon than the Order 1 Soils survey had recommended. The result of these <br />extended salvage depths appears to affirm that the state has authorized the mine operator to <br />salvage and use a large proportion (around 50 %) of the B lift to consist of C horizon materials <br />(an average of 28 inches of C horizon materials to be salvaged from Zone 4 and redistributed in <br />Zones 3 and 4). <br />As described earlier in this report, much of the C horizon materials (particularly the deeper <br />portions of this horizon) have excessive calcium carbonate content as well as a high rock content, <br />rendering most of this material as unsuitable for use as a subsoil (B lift) in reclaiming prime <br />farmlands. Mixing the low quality C horizon materials with the higher quality B horizon <br />materials in such a great proportion (50/50) runs a high risk of significantly degrading the quality <br />12 <br />