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2010-08-10_REVISION - C1981008 (3)
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2010-08-10_REVISION - C1981008 (3)
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Last modified
8/24/2016 4:17:44 PM
Creation date
8/18/2010 5:18:00 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
Revision
Doc Date
8/10/2010
Doc Name
Response 4 Revised Section 2.04.9
From
Western Fuels-Colorado
To
DRMS
Type & Sequence
PR6
Media Type
D
Archive
No
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Based on this conclusion, a major effort was made to revise the topsoil handling procedures to <br />account for the prime farmland soils. This work was done in the latter part of 2008 and the early <br />part of 2009 under Technical Revision 57, which was submitted to the DRMS in March 2008. Very <br />specific and detailed soil stripping and replacement procedures were developed in this Revision <br />accounting for the prime farmland soils in the permit area. It was later realized by all parties that <br />the term "prime farmland ", as described in the previous letters, needed clarification. Basically, <br />prime farmland only exists where there is an adequate and dependable supply of water and the <br />land must be economically viable to irrigate and farm. This is important since some areas of prime <br />farmland soil may exist which are not truly prime farmlands. Examples of these situations follow: <br />a) Areas which may have not been historically farmed in the past for any number of reasons <br />b) Areas which are too small to irrigate efficiently and economically <br />c) Areas which may have been irrigated in the past but the water no longer exists to permit an <br />adequate and dependable supply. <br />This issue was clarified in the August June 27, 2008 letter from Jim Boyd of the NRCS to Dan <br />Mathews of the DRMS, which is also included in Attachment 2.04.9 -5a. Basically, Jim Boyd states <br />that prime farmlands lose this status if an adequate and dependable supply of water does not exist. <br />Therefore, all previous references to prime farmland have now been referred to as prime farmland <br />soils. Each individual parcel is then subject to evaluation to determine if it truly meets the definition <br />of prime farmland. WFC acknowledges that all 98A and 98E soils are otp ential prime farmlands <br />and all of these soils will be handled under the detailed topsoil stripping, handling, storage and <br />replacement procedures of this Section 2.04.9 and Section 2.05.4 2(d), as of February 2008, when <br />the determination of potential prime farmland was made by the NRCS. <br />As of February, 2008, the eastern portion of the Morgan fields in the permit area, which are in <br />prime farmland soils (west of 2700 Road and south of BB Road) has been backfilled with Subsoil <br />Substitute. The Bench 1 substitute subsoil material is sampled prior to topsoil replacement to <br />demonstrate that the material meets the suitability criteria of Table 2.05.4(2)(d) -1A. Initial testing <br />was performed by Walsh Environmental Scientists and Engineers, Inc. (Walsh) in 2008 (see Walsh <br />report in Attachment 2.05.4(2)(d). <br />(Revised July 2010) 2.04.9 -11 <br />
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