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DMG requests that, upon completion of the initial sampling associated with <br />CRDA and RSRDA reclamation projects, a minor revisicn report be prepared and <br />submitted that summarizes the sampling results and assesses the extent to <br />which replaced soils met or did not meet permit specified subsoil or topsoil <br />quality limits. <br />The Solis information included in the TR-42 application is, in essence, the report <br />requested in the April 2002 inspection report. DMG's review of the TR-42 soils report is <br />summarized here below. <br />CRDA- <br />Data indicates that CRDA-2 subsoil was relatively high quality, with only 1 minor <br />exceedance of the EC criteria out of 15 samples, and no exceedances of the SAR <br />criteria. Sample data was apparently not provided for the 6 inch respread topsoil layer at <br />CRDA-2. Narrative refers to Subsoil Sample #s CRDA2-1 through CRDA2-12, however <br />three additional samples not referenced in the narrative (13, 14, and 15) are listed on the <br />CRDA 2 Subsoil Analysis Table. <br />CRDA-1 <br />CRDA-1 respread soils data apparently reflect sampling of the entire 18 inch cover soil <br />thickness (subsoil and topdressing combined). The material in general meets the subsoil <br />criteria (only three of 16 samples exceeded either EC or SAR criteria). However, 12 of <br />the 16 samples exceeded the topsoil criteria for either or both parameters. Average EC <br />value was 11.0, average SAR value was 11.7, wmpared to permit threshold levels for <br />topsoil of 8 (EC) and 72 (SAR), respectively. Page 9-5 of the amended narrative <br />indicates that all of the cover material for CRDA-1 was borrowed from CBA-2, "...with no <br />separate accounting for topsoil", so presumably there would be no difference in quality <br />between the upper 8 inch layer and lower 12 inch layer of replaced soil on CRDA-1. <br />CBA-2 data indicate that only two of nine sampled zones met specified topsoil criteria for <br />both parameters. Subsoil criteria were met ar only slightly exceeded, with the exception <br />of one extreme SAR value (SAR=61) from a sample adjacent to Coal Gulch (apparently <br />reflective of the high sodium soils that were avoided). Soil salvaged from CBA-2 and <br />replaced on CRDA-1 appears to have bean somewhat higher quality than the soil <br />available in Soil Stockpile 2, marginally lower quality than than Stockpile 1, and <br />comparable to the soil available from Stockpile 3 (see table below). <br />Sampled Area EC (ova.) SAR (avo.l <br />CRDA-1 Cover Soil 11.0 11.72 <br />Topsoil Pile 1 7.8 11.54 <br />Topsoil Pile 2 13.3 18.01 <br />Topsoil Pile 3 8.0 14.0 <br />There would appear to have been no appreciable benefit gained from using some <br />combination of available topsoil stockpiles for topdressing, as opposed to use of the <br />CBA-2 borrow material. (Topsoil Pile 1 was marginally higher quality, but use of Topsoil <br />Pile 1 would have "robbed" the material from the North Portal Reclamation project, and <br />various other areas to be reclaimed). Original permit projections regarding the availability <br />of sufficient material meeting "topsoil" criteria within approved stockpiles and designated <br />borrow areas in the vicinity of the North Portal and CRDA refuse areas were apparently <br />erroneous. <br />