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2008-05-28_REVISION - C1981008
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2008-05-28_REVISION - C1981008
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Last modified
8/24/2016 3:32:07 PM
Creation date
6/2/2008 2:55:18 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
REVISION
Doc Date
5/28/2008
Doc Name
Preliminary Adequacy Review Letter
From
DRMS
To
Western Fuels-Colorado
Type & Sequence
TR57
Email Name
MLT
Media Type
D
Archive
No
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than twice as high as the 1:1 extract value, which is the case with all 6 of the <br />samples for which values are reported for the two different extracts. It may be the <br />case that one or more of the second round samples (e.g. SS-21, SS-26, SS-32, and <br />SS-33) would also exceed the standard, if analytical values based on Saturated <br />Paste extract were reported. <br />Please provide lab sheets with'saturated paste extract based pH and EC <br />values for all of the samples collected from the 2.5 acre grid. If the lab did not <br />provide Saturated Paste Extract pH and EC analyses for the subject samples, <br />re-sampling of the grid will be required. For any sample sites that exceed the <br />criteria based on Saturated Paste Extract values, the more intensive <br />sampling investigation and mitigation protocol specified in the final <br />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 <br />duplicative (there are a couple tables included in one but not the other). There <br />would appear to be no reason for the two separate attachments, and having two <br />attachments that are almost but not exactly the same creates some confusion. <br />Please consolidate the information from the two attachments into a single <br />attachment, and amend the application to contain only the single <br />comprehensive attachment. <br />36. The "Maintenance and Testing Procedure" narrative on page (d)-33 is somewhat <br />outdated, due to the additional parameters (Table 2.04.9-2), more intensive <br />sample grid, and required analysis of individual samples rather than composite <br />samples, associated with the sampling programs described on pages (d)-28 <br />through (d)-30, which address both topsoil and subsoil testing. Please amend the <br />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 <br />method and type of equipment to be used for removal, storage, and <br />replacement of soil in accordance with Rule 4.25, pursuant to Rule <br />2.06.6(2)(b). <br />38. Rule 4.25.3(1) requires segregation of the A horizon of the natural soil, except <br />where it can be shown that other available soil materials will create a final soil <br />having a greater productive capacity... <br />The salvage plan presented in the application would include upper portions of the <br />B horizon, in addition to the A horizon, in the upper lift. This approach may be <br />approvable for the soil types in the 98E map unit, due to practical considerations <br />associated with the typically thin A horizons and lack of clear visual distinction <br />10
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