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(i) 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 of field -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 />Confusing and Technically Unsupportable Sampling Methods Employed for <br />Demonstrating the Quality of Soil/Spoil Substitute Materials used for Reclamation of <br />Prime Farmlands <br />Sampling of regraded spoil and soil is conducted to ensure that the materials used as the growth <br />medium for the prime farmlands are not toxic and/or acid forming, leading to a detrimental <br />impact to revegetation efforts during reclamation (4.05.8(1)). Chemical and physical parameters <br />identified as being potentially toxic to plants have threshold suitability criteria established for <br />them (see above discussion). If regraded spoils and/or respread soils exceed the established <br />suitability criteria, a mitigation plan must be developed and implemented. If sampled spoil/soils <br />comply with the established criteria, reclamation may be considered acceptable. WFC's <br />sampling and mitigation plan can be found in sections 4.0, 5.0 and section 2.05.4(2) (d) of the <br />permit. <br />Sampling of the regraded and redistributed material must be conducted in an unbiased manner. <br />Typical industry practice is to sample systematically. As described in the permit, the mine <br />operator takes a soil sample every 2.5 acres in all four reclamation plan zones of the Morgan <br />property. This sampling location frequency is typical for the mining industry. On the other <br />hand, at these sample locations this permit allows the mine operator to take a max 2 foot depth <br />composite sample for the Lift A (mixed A/B horizons) topsoil in all four reclamation zones, and <br />the Lift B (mixed B/C horizons) subsoil in Zones 3 and 4. For reclamation Zones 1 and 2, a <br />singular 33 inch composite sample is allowed for the Bench 1 subsoil substitute material. This <br />sampling methodology does not represent typical practice for the industry. These large sampling <br />depth intervals run considerable risk of not accurately depicting the chemical and physical <br />variability of the soil/spoil and therefore may not contain data findings representative of the <br />quality of the growth media being evaluated. <br />Permit page 2.05.4(2) (d) -46 includes a discussion of the mitigation plan to be employed when <br />unsuitable spoil /soil is encountered. The plans for remediating Bench 1 overburden substitute . <br />and the top /subsoils that don't comply with the suitability criteria, have the same requirements. <br />If an unsuitable parameter is encountered, the mine operator is to resample the soils as addressed <br />in the following statement from the permit: "This sampling will be called the 2d Phase sampling <br />and the interval is one hole per 50 feet distance around the bad point in all directions for prime <br />18 <br />