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Reclaimed Areas <br />WFC has updated the soil substitute redistribution section of the proposed revision application to <br />reflect how the soil test pit locations were chosen and identified on the map. WFC's response is <br />adequate and has satisfactorily addressed the review comments /concerns we had previously <br />discussed in our October 14, 2011, letter. <br />Stockpiled Soil Resources <br />WFC has updated the undisturbed native soil section of the revision application to reflect how <br />the soil test pit locations were chosen and identified on the map, satisfactorily addressing this <br />previously listed deficiency. <br />WFC provided additional details requested by OSM, including the physical particulars of the _ <br />stockpiles, how the sample locations were identified selected, and a plan for sampling within <br />the stockpile if the soil probe is unable to penetrate the stockpile at a given depth. Regarding this <br />latter issue, the proposed plan has two sampling intervals. The first sampling interval is to <br />address the soil quality within the top 3 /4 of the stockpile, while the second interval of the plan <br />addresses the bottom 1 /4 of the stockpile. For the first interval, if /when impermeable materials are <br />encountered, the plan proposes to move the soil probe 1 foot to the right of the previous sampling <br />location and obtain new samples from this alternate probe location. For the second interval, <br />where sampling has begun for the last quarter probe length of the stockpile and impermeable <br />materials are encountered with the probe, "(a) the location will be sampled to maximum depth <br />possible and samples will be collected from the last quarter from the materials that is available, <br />(b) total sampling depth of the location will be recorded, and (c) information regarding the type <br />of refusal that was encountered will be investigated and recorded." Under this second interval <br />scenario, WFC is not proposing to move right by one foot and resample as proposed in the first <br />sample interval material in the upper 3 /4 of the topsoil pile. Rather, for the second interval (last 1 /4 <br />of probe) the plan is proposing to stop sampling at the restricted depth. OSM interprets the intent <br />of not sampling the material below the impermeable layer as acquiescing that all soil material <br />below this layer is defined as unsuitable for use in prime farmland reclamation. If this is not <br />what WFC had intended within the proposed sampling plan, what is intended needs to be <br />clarified further. <br />Due to WFC providing the physical details of the topsoil piles such as their volume and height, <br />OSM is in a position of more thoroughly evaluating the sampling plan. The plan states that each <br />soil boring will have 4 samples taken. This means that the largest Lift B stockpile (40 feet in <br />height) will only have 4 samples taken for each boring/probe, representing four composite <br />samples each being. 10 feet in thickness. On the other hand, mixed topsoil piles that are 20 feet <br />and 15 feet in height have composite sample segments that represent 5 feet and 3.75 feet, <br />respectively. The Lift A soil is stored within two piles, one that is 30 feet high and one that is 7 <br />feet high, with composite sample segments representing 7.5 feet and 1.75 feet. It is OSM's view <br />that the composite sample segments for the Lift B and the largest Lift A stockpiles are excessive <br />(being 10 feet and 7.5 feet respectively), and unnecessarily increase the risk of not adequately <br />defining the quality of the soil materials within these stockpiles; particularly in comparison to the <br />far smaller composite sample segments within all other stockpiles being sampled. For proper <br />quality control there is a need for the probe locations within the Lift B stockpile to consist of 8 <br />composite samples (rather than four) and for the large Lift A stockpile to consist of 6 composite <br />