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C- 1981 -008 August 25, 2010 <br />PR -06 AR #5 Page 3 of 26 <br />of Attachment 2.04.9 -5. Please correct the improperly worded statement (should be written <br />as a single sentence rather than two sentences) in both the Section table of contents and on <br />the Attachment notation. <br />b. The Division had requested text reference to certain MRCS documentation addressing <br />erroneous information regarding prime farmland criteria. The requested reference was <br />provided. Item 4B(b) Resolved <br />4C. This item was incorporated in Item 14 of the 7123110 adequacy letter. See Item 14. <br />4D. This item requested additional explanation regarding MRCS letter of October 1.4, 1992, which <br />provided a negative prime farmland determination for Barx soils within the original 220 -acre NH <br />Mine 2 (formerly Nucla East) permit area, in the southeastern portion of the current permit area. <br />There is some uncertainty as to whether the letter was intended to apply to a 21acre area of D70B <br />(Barx Scalped/Barx Buried Complex) soil within the area (as mapped by Peabody), or solely to a <br />1.1.9 acre area of Unit 15 (Barx) soil in the extreme SE corner of the permit, as indicated on the <br />NRCS soil survey. <br />WFC addressed this matter in amended narrative of Section 2.04.9, within subsection 10.1 and <br />subsection 10.4, Item 1. We have the following additional requests, based on review of the <br />amended materials: <br />a. In the first sentence of amended subsection 10.1, "Prime Farmland Determination — 1988 and <br />1998 ", WFC references the current version of National Soil Survey Handbook (NSSH) <br />Chapter 657.5 prime farmland criteria. At the end of the sentence, it is indicated that the <br />criteria are "for the initial permit ". The current 657.5 criteria, dated January 1, 2000, would <br />apply to the entire permit area, not just the initial permit. Please delete the clause "for the <br />initial permit" at the end of the 1 St sentence of subsection 10.1. <br />b. Further along in the subsection 10.1 narrative, there is a sentence that states "Soil type 70B <br />and D70B lists Barx soil as a major component and Barx as a secondary component (30 <br />percent of map unit) in 98E on Map 2.04.9 -1 ". This sentence is incorrectly written. Please <br />restate as follows: `Barx soil is a major of component of Map Units 70B and D70B, and a <br />secondary component of Map Unit 98E (30% of unit), listed on Map 2.04.9 -1." <br />c. As detailed in the Introduction to Section 2.04.9, three separate soil surveys were conducted. <br />Subsection 10.1 fails to include the 1996 survey conducted for PR -04 by IRL Please revise <br />the text in the second paragraph of 10.1 to include reference to the 1996 survey and to the <br />1996 letter from the MRCS that addressed the issue prime farmlands for PR -04. <br />d. Toward the end of subsection 10.1 narrative, there is a sentence that states "the October 1992 <br />NRCS letter was misinterpreted by DRMS..." Please either delete "by DRMS" or rephrase <br />to state "by WFC and DRMS..." <br />4F -4G. Previously Resolved. <br />4H. See Comment 4D. <br />4I. The Division requested clarification regarding "prime farmlands" vs. "prime farmland soils ". <br />Acceptable wording in response to the Division's request was incorporated into the narrative of <br />subsection 10.4, Item 2. Several sentences regarding Morgan lands in the permit area are <br />