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2008-10-01_REVISION - C1981008
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2008-10-01_REVISION - C1981008
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Last modified
8/24/2016 3:36:48 PM
Creation date
10/2/2008 1:14:58 PM
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
REVISION
Doc Date
10/1/2008
Doc Name
Review and Response Memo
From
Dan Mathews
To
Marcia Talvitie
Type & Sequence
TR57
Email Name
DTM
Media Type
D
Archive
No
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Dearstyne, NRCS Soil Scientist. Narrative regarding the re-sampling conducted <br />in response to this item is discussed in amended Attachment 2.05.4(2)(d)-1 <br />"Walsh Report on Subsoil Suitability February 2008 (Revised July 2008)", on <br />page (d)-1-4 of the Attachment. Subsoil sample locations are depicted on Figure <br />1 of the Attachment; March 5, 2008 sample results based on 1:1 extract and June <br />25, 2008 re-sample results based on saturated paste extract for 8 of the original <br />sample locations are reported in Table 2 of the Attachment. <br />June 2008 re-sample results show that two of the 8 subsoil locations exceeded the <br />4.0 mmhos standard of Table 2.05.4(2)(d)-1; one by a slight margin (Sample # 21, <br />4.34), and one by a wider margin (Sample #32, 7.33). <br />On amended narrative page 2.05.4(2)(d)-32, the operator indicates that "...Bench <br />1 subsoil was primarily suitable for all tested criteria. Two samples exceeded the <br />conductivity standard by a small amount." We would agree that the 4.34 mmhos <br />value for Sample #21 represents exceedance by a small amount; however the <br />Sample #32 value of 7.33 mmhos is of concern; it exceeds the specified standard <br />by a significant margin, and also exceeds the 6.0 mmhos value apparently <br />indicated by Dan Dearstyne of NRCS, as potentially being acceptable as an upper <br />limit for prime farmland subsoils (based on reference to discussion with Mr. <br />Dearstyne in amended Attachment 2.05.4(2)(d)-1). <br />Based on the re-sample results, the more intensive sampling program described on <br />amended pages 2.05.4(2)(d)-31 and (d)-32 for prime farmland subsoil is <br />warranted with respect to Sample #32 conductivity. Remedial soil handling in the <br />Sample #32 vicinity may be warranted, depending on the results of the additional <br />intensive sampling (as described in the plan on amended pages 2.05.4(2)(d)-31 <br />and (d)-32). Please revise the second paragraph of amended narrative page <br />2.05A(2)(d)-32 to more accurately characterize the results of the June 2008 <br />re-sampling for conductivity, and commit to implementation of the remedial <br />sampling/soil handling plan with respect to Sample Site #32, for conductivity. <br />39. The Division's original Item 39 comment stated the following: <br />Note that the revegetation success demonstration requirements for prime <br />farmland crop production, as outlined in Rule 4.25.5(3), differ in some <br />respects from the requirements applicable to non prime farmland crop <br />production. Please include a narrative section describing the specific <br />approaches and procedures that will be employed to demonstrate success of <br />revegetation for prime farmland areas. <br />Although the Table of Contents for amended Section 2.05.4(2)(d) lists a sub- <br />section titled "Prime Farmland Revegetation Success Standards", no such section <br />was included in the amended narrative. On further consideration, it may be <br />appropriate that the necessary prime farmland revegetation success standards and <br />success demonstration methods section be addressed within a new sub-section of <br />5
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