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(see above cited technical evaluation report attached to OSM's August 1, 2011, letter). <br />Similar to the Undisturbed Native Soil sites the random samples were first stratified within the <br />"redistributed (See Map 2.04.9 -3)" areas and then randomized within those strata. The strata were <br />defined by breaking the redistributed area into three segments.. <br />The language in the Key -Ag SAP has been modified to accurately reflect the number of sample points <br />in this area as well as clarify the sampling plan for this area. <br />Stockpiled Soil Resources <br />In addition to the above, TR -61 addresses the sampling of soil materials previously placed in stockpiles that <br />are located on the Morgan property. These soil materials were salvaged from the Morgan property prior to <br />mining activities. WFC's proposed plan for sampling/analyzing the stockpiled soil materials includes <br />statements claming that "approximately five or 10 borings were randomly placed across the stockpiles" and <br />that "The borings will be conducted so that the entire depth of material is evaluated. "It is understood that <br />each boring is to have 4 samples taken from each core. The plan should include language claming how <br />the number of borings for each stockpile were chosen, the approximate volume of material each of the 4 core <br />samples are to represent, and the details of the method to be used for randomly selecting the sample <br />locations. In addition, details identifiiing the physical particulars of the stockpiles, including their depth <br />and/or height, volume, and surface acreage footprint, need to be provided OSMis unable to complete an <br />evaluation of this key portion of the proposed revision application plan, until more details are provided. <br />The proposed sampling plan needs to include a protocol in place to address occasions when the soil probe is <br />unable to penetrate the stockpiles to the desired depth, due to the occurrence of rock and/or other impermeable <br />materials that may be present. The protocol should address the recording of the encountering of large rocks <br />with the soil probe, the methodology for selecting a new sampling location if /when rocks are encountered <br />with the soil probe, and how thus identified rocky soil materials will be addressed in determining permit <br />suitability requirements. To help to determine the amount of course rockfragment material that has been <br />salvaged with the suitable soil, the revision application includes language indicating that pits will be <br />excavated to a depth of 20 feet to visually observe the rock content. This additional sampling is critical in <br />determining the suitability of the material as related to rockfragment percentage. <br />The sampling locations on the stockpiles were randomly selected by GLA in consultation with Key -Ag <br />and DRMS. Five locations are used for the two small stockpiles due to the limited size of the piles, while <br />ten locations are placed on the larger stockpiles in order to ensure a comprehensive understanding of <br />the material in each stockpile. The four core samples will be obtained from each quarter of the total <br />depth/height of the stockpile soil resource. None of the individual 40 (large stockpile) or 20 (smaller <br />stockpiles) samples will represent a given volume or quantity of the stockpile. It is intended that the <br />samples will be utilized to estimate the mean soil physical and chemical properties of the entire sampled <br />material <br />The physical parameters of the stockpiles (footprint, height, and volume) are shown on Map 2.04.9 -3 <br />and in the Key -Ag SAP. <br />The SAP has been updated to reflect information regarding how sampling will be performed if refusal <br />is encountered during the sampling of the stockpiles. In general if refusal is encountered the following <br />