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2010-04-06_REVISION - C1981008
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2010-04-06_REVISION - C1981008
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Last modified
8/24/2016 4:03:26 PM
Creation date
4/30/2010 9:49:29 AM
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
Revision
Doc Date
4/6/2010
Doc Name
Supplemental Adequacy Review and Follow-up to Informal Conference
From
DRMS
To
Western Fuels Colorado
Type & Sequence
PR6
Email Name
MLT
SB1
Media Type
D
Archive
No
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C- 1981 -008 PR -06 06- Apr -2010 <br />PAR - Supplemental Page 5 of 7 <br />Section 2 - Additional Items from Informal Conference <br />75. Please provide additional detail regarding fertilization rates and practices for irrigated <br />pastureland and irrigated cropland postrnining land use areas, pursuant to Rules 4.06.5, <br />4.15.7(5)(d) and 4.15.7(5)(e), and (for Prime Farmland--4.25.4(6)). Please address <br />measures to ensure that fertilizer management for reclaimed lands and reference areas <br />during bond release demonstration years will be similar. <br />76. There is confusion regarding the tables for soil suitability in the permit. Table 2.04.9 -2 <br />titled, "Criteria for Evaluating Soil Suitability" was used in the baseline soil survey to <br />evaluate the soil salvage criteria. Table 2.05.4(2) (d) -1 is also titled "Criteria for <br />Evaluating Soil Suitability ". Table 2.05.4(2) (d) -1 is part of the reclamation plan and <br />lists the soil replacement criteria. The two tables are very similar with one exception. <br />Table 2.05.4(2) (d) -1 has a threshold limit for conductivity for Prime Farmland Lift B and <br />Single -Lift Soils of 6.0, as opposed to the 4.0 limit used for the baseline survey in Table <br />2.04.9 -2. The soil conductivity replacement limit was raised because several of the initial <br />Bench 1 (substitute subsoil) soil samples exceeded 4.0 (after re- analysis using a saturated <br />paste extract rather than 1:1 extract that was employed initially). Footnote 2, to the table <br />provides narrative explanation for the 6.0 EC level. <br />The Division asked Dave Dearstyne of the NRCS about the suitability of the 6.0 salinity <br />level. He felt the criteria of 6.0 for individual locations was acceptable, but that an <br />additional requirement for an over -all average level of 4.0 to 5.0 mmhos might be <br />appropriate for the prime farmland lift B (subsoil) and non -prime single lift soils. Mr. <br />Dearstyne also indicated that continued sampling and analysis for selenium in the soils <br />and surface spoil at New Horizon was not warranted, due to the very low component of <br />selenium in the soils and Dakota formation overburden. Please modify the permit to <br />delete the selenium requirement and revise the Prime Farmland Lift B and Single Lift EC <br />criteria to specify a limit of 6.0 mmhos at a single location; with a 5.0 mmhos average for <br />a particular landowner's soil replacement acreage. <br />The soil parameter tables should include the applicable measurement units for specific <br />parameters, with footnote reference to applicable analytical method. The Division also <br />recommends that Table 2.05.4(2)(d) -1 be renamed "Criteria for Evaluating Soil <br />Replacement Suitablity "to differentiate the two tables. <br />77. There are formatting problems with the version of Table 2.04.9 -1 included in the PR -6 <br />application. Please amend the table as warranted. <br />78. There is some confusion created by the fact that there are two overlapping sampling <br />requirements for subsoil and surface spoil. There is a 600' grid for regraded spoil, and a <br />more recent (TR -57) 330' sample grid approved in TR -57 that includes "Bench 1 <br />Suitable Subsoil ", which is in fact surface spoil. The 330' grid would be appropriate for <br />Prime Farmland areas, while the 600' grid would be appropriate for other areas. For <br />clarity, please provide amended narrative within a single location in Section 2.05.4(2)(d), <br />to describe the sample grid and parameters applicable for Prime Farmland topsoil lift A <br />
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