2008-05-28_REVISION - C1981019 - Laserfiche WebLink

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From the Division's point of view, the portion of the sentence after the first comma raises alarms, because it could be interpreted as implying that that "anything goes" with respect to topsoil replacement, and that the field construction supervisor would have freedom of choice with respect to decisions pertaining to topsoil replacement thickness. The Division doubts this is what was intended, and the Division requests that the language be deleted or properly qualified. The Division suggests the sentence be revised as follows. The primary `foundation building" element for this approach is the ability to replace variable topsoil depths and/or quality of soil materials depending on site-specific needs, as more specifically described under "Topsoil Redistribution Plan" of this section. b) On amended page 2.05-46, at the end of the 2°d paragraph of the Topsoil Redistribution Plan, narrative states that topsoil will be "redistributed and graded to an average or variable replacement depth shown in Section 4.06". This is confusing because Section 4.06 of Volume 1 was not updated in the TR-72 submittal, and thus does not contain details regarding the variable thickness redistribution plan. Sections of Volume 12 (South Taylor Topsoil Plan) pertaining to topsoil replacement were also not updated in TR-72, and may contain information that will no longer apply, following approval of TR-72. Please delete the reference to Section 4.06 on amended page 2.05-46, or provide a revised Section 4.06 that includes a revised, detailed, soil replacement plan. The reference to Section 4.06 should specify which Section 4.06 is intended (presumably Volume 1), and outdated information in Volume 12, Sections 2.05.4 and 4.06 should be amended as warranted. There is no need for the topsoil replacement plan narrative to be spread through multiple sections in multiple volumes; the Division's preference is that the narrative plan be comprehensively addressed within a single section of the application, to be referenced within other sections as warranted. c) The topsoil replacement narrative pertaining to replacement thickness, which begins following the excerpted paragraph from the CDOW letter on amended page 2.05-47, is overly vague and conceptual; additional details and commitments are necessary to provide a plan that will demonstrate conformance with Rule 4.06.4(2)(a). The only reference to specific replacement thickness variation is at the bottom of page 2.05-47, where shallow lifts are described as "less than 8 inches" and thicker lifts are described as "greater than 8 inches". This does not necessarily equate to the "dramatic variation" in topsoil depth recommended in the CDOW letter, and does not provide the detail regarding replacement thickness required by 4.06.4(2)(a). The Division also notes a potentially misleading reference to "the currently approved 8 inch average", in the first sentence on page 2.05-48. The 8 inch average is applicable only to areas within the "original" permit boundary; the currently approved average replacement thickness for the South Taylor revision area is 19.8 inches. Please revise the Topsoil Redistribution Plan narrative beginning on the second half of page 2.05- 47, to replace the current conceptual discussion (and misleading reference to currently approved 8 inch average), with a more defined plan. The amended narrative will need to incorporate the concepts discussed, including significant variation in replacement thickness, into a plan that will demonstrate compliance with 4.06.4(2)(a). In addition, please provide a Topsoil Replacement Map or Maps with PMT base covering the entire post-2008 reclamation area, delineating parcels or zones with specified average uniform topsoil replacement thickness. The replacement parcels within which defined optional treatments such as the "soil fence berms" or "thick and thin disarray" might be implemented, should be specified, and the approximate maximum extent of