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exceeding the 4.0 mmho/cm standard. The Saturated Paste extract value is more than twice <br />as high as the 1:1 extract value, which is the case with a116 of the samples for which values <br />are reported for the two different extracts. It may be the case that one or more of the second <br />round samples (e.g. SS-21, SS-26, SS-32, and SS-33) would also exceed the standard, if <br />analytical values based on Saturated Paste extract were reported. <br />Please provide lab sheets with saturated paste extract based pH and EC values for all <br />of the samples collected from the 2.5 acre grid. If the lab did not provide Saturated <br />Paste Extract pH and EC analyses for the subject samples, re-sampling of the grid will <br />be required. For any sample sites that exceed the criteria based on Saturated Paste <br />Extract values, the more intensive sampling investigation and mitigation protocol <br />specified in the final paragraph of page 2.05.4(2)(d)-28 will be required. <br />35. Attachments 2.04.9-11 and 2.05.4(2)(d)-1 are largely, but not completely duplicative (there <br />are a couple tables included in one but not the other). There would appear to be no reason <br />for the two separate attachments, and having two attachments that are almost but not exactly <br />the same creates some confusion. Please consolidate the information from the two <br />attachments into a single attachment, and amend the application to contain only the <br />single comprehensive attachment. <br />36. The "Maintenance and Testing Procedure" narrative on page (d)-33 is somewhat outdated, <br />due to the additional parameters (Table 2.04.9-2), more intensive sample grid, and required <br />analysis of individual samples rather than composite samples, associated with the sampling <br />programs described on pages (d)-28 through (d)-30, which address both topsoil and subsoil <br />testing. Please amend the section as appropriate to eliminate confusion. <br />Comments Specific to Prime Farmland Re ug latory Requirements <br />37. Please specify, within the appropriate application section, the proposed method and <br />type of equipment to be used for removal, storage, and replacement of soil in <br />accordance with Rule 4.25, pursuant to Rule 2.06.6(2)(b). <br />38. Rule 4.25.3(1) requires segregation of the A horizon of the natural soil, except where it can <br />be shown that other available soil materials will create a final soil having a greater <br />productive capacity... <br />The salvage plan presented in the application would include upper portions of the B horizon, <br />in addition to the A horizon, in the upper lift. This approach may be approvable for the soil <br />types in the 98E map unit, due to practical considerations associated with the typically thin <br />A horizons and lack of clear visual distinction between the A and upper B horizons. Please <br />address this provision and provide appropriate documentation to support the proposed <br />approach. <br />39. Note that the revegetation success demonstration requirements for prime farmland crop <br />production, as outlined in Rule 4.25.5(3), differ in some respects from the requirements <br />9 <br />