2011-10-24_REVISION - C1981008 (4)

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OSM Review Comments Undisturbed Native Soil Proposed within the permit revision application is a plan to conduct a soil survey on the undisturbed portion of the Morgan property. The revision application includes the following statement; "Soil sampling locations will be determined by randomly placing geo- referenced sample location prior to going to the field (see Map 2.04.9 -3) ". It is understood that these locations are to be randomly selected; however, WFC needs to clam and explain in what manner these locations have been determined to be random, and should sped the acreage of the area that contains the undisturbed soil. OSM assumes these sample locations have already been selected since they are shown on Map 2.04.9 -3. The location of the sample points in the undisturbed portions of the Morgan Property shown on Map 2.04.9 -3 were randomly generated by Greg Lewicki and Associates in consultation with Key -Ag and DRMS. These locations are meant to guide sampling in the field, but Key - Ag personnel may adjust the sample locations in the field if deemed necessary, and such changes will be reflected in the SAP results when they are submitted. The proposed soil sampling points locations were based on a stratified random sampling from undisturbed areas, within the permitted mine site. The stratified portion of the sampling was based on information obtained from previous soils work completed and locations where additional soils information could be useful. The points, within the stratified areas were placed randomly using the outline of the area of interest. Selection of random points prior to sampling within the stratified areas will minimize sampler bias in the field. The three samples located in the western approximately 9.49 acre portion of the undisturbed areas are intended to assist in better identifying the soils present in this area. The two samples locations shown in the southern, approximately 1.90 acre portion of the field will assist in defining the soil(s) present in this area. The newly obtained undisturbed soil sampling location will be used in conjunction with previously collected data to better understand the soil pedology of the entire mined area and could provide critical data on what the prime farmland in this field could have looked (physically, chemically, and morphologically) like prior to mining. The areas of undisturbed soils being sampled are shown on Map 2.04.9 -3 (11.39 acres). The locations of the soil test pits in the undisturbed area have been preliminarily selected but may need to be adjusted in the field based on actual field conditions. If any field adjustments need to be made those adjustments will be conducted by a Certified Professional Soil Scientist in consultation with the NRCS, DRMS, and OSM representatives prior to sampling. Reclaimed Areas The permit revision application also includes a proposal to sample reclaimed areas on the Morgan property. The revision application contains language indicating that one test pit will be excavated with a backhoe, although Map 2.04.9 -3 shows that three locations have been preselected. The plan should include language claming how many locations will be excavated, and again, a detailing of the methods used to randomly select these sample locations. It is understood that this sampling/analysis is to be used as an initial step in the process/discussion for determining whether the use of a soil substitute is appropriate in the place of prime farmland soils. Further discussions on this subject will be needed once the sample data is obtained