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1 samples analyzed, a couple had EC's exceeding the suitability criteria and six others had EC's <br />nearing the maximum of 4 mmhos /cm allowed in the permit prior to the PR -6 revision approval. <br />For perspective, it should further be noted that the B horizon soils that existed prior to mining <br />had an average EC of 1.8 mmhos/cm and none exceeded 4. The applicable state regulations <br />addressing the requirements for using a substitute for the reclamation of prime farmlands in lieu <br />of using the existing B horizon subsoil present before mining, read as follows: <br />4.06.2(4) (a) <br />Selected overburden materials may be substituted for, or used as supplement to topsoil, <br />if the Division determines that the resulting soil medium is equal to or more suitable for <br />sustaining the vegetation than is the available topsoil and the resulting soil medium is the <br />best available in the permit area to support revegetation. This determination shall be <br />based on: <br />(1) The results of chemical and physical analyses of overburden and topsoil. These <br />analyses shall include thickness of soil horizons, total depth, texture, percent coarse <br />fragments, areal extent of the different soils and materials, determinations of pH, net <br />acidity or alkalinity, phosphorus, potassium, texture class, electrical conductivity, sodium <br />absorption ratio, and other analyses as required by the Division. The Division may also <br />require that results offield -site trials or greenhouse tests be used to demonstrate the <br />feasibility of using these overburden materials. <br />(ii) The trials and tests shall be conducted using standard procedures approved by the <br />Division. <br />2.06.6(2) (d) <br />If applicable, documentation, such as agricultural school studies or other scientific data <br />from comparable areas, that supports the use of other suitable material, instead of the A, <br />B, or C soil horizons, to obtain on the restored area equivalent or higher levels of yield <br />as non -mined prime farmlands in the surrounding area under equivalent levels of <br />management. <br />2.04.9(3) <br />Where the applicant proposes to use selected overburden materials as a supplement or <br />substitute to topsoil, the application shall provide results of the analyses, trials, and tests <br />required under 4.06.2. <br />Regarding the above cited Walsh Report's recommended use of the Bench 1 overburden in prime <br />farmland reclamation, this report concludes with the following statement: "The bench 1 <br />material......has characteristics of suitable subsoil for use during reclamation, with the <br />exception of elevated EC at one or two locations ". An important distinction is necessary <br />regarding this conclusion the report does not conclude or address the question of whether <br />the Bench 1 overburden material is a capable substitute for restoring the yield potential of the <br />prime farmland subsoil (i.e. the B horizon materials) that existed prior to mining disturbance. As <br />10 <br />