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2010-09-22_REVISION - C1981008
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2010-09-22_REVISION - C1981008
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Last modified
8/24/2016 4:23:20 PM
Creation date
9/22/2010 5:00:56 PM
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
Revision
Doc Date
9/22/2010
Doc Name
Response to Adequacy No. 5
From
Greg Lewicki & Associates
To
DRMS
Type & Sequence
PR6
Email Name
MLT
SB1
Media Type
D
Archive
No
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78A. Resolved. <br />78B. Please see Comment 76F above, and respond accordingly. See Item 76F. <br />78C. The Division pointed out a typographical error in the heading of Subsection 6.0. The typo was <br />corrected in the amended text. Resolved. <br />78D. The Division requested clarification of the Unsuitable Spoil Mitigation Plan, in Subsection 5.0 of <br />Section 2.05.4(2)(d). Requested clarification was provided. Resolved. <br />78E. The Division made two requests regarding reorganized Subsections 14.0 and 15.0. <br />a. The Division requested clarification regarding soil replacement lift thickness documentation <br />and reporting for non -prime farmland areas. Adequate clarification was provided in <br />amended Subsection 14.0, however there is an extraneous sentence fragment in the final <br />paragraph of Subsection 14.0 (`Replacement depth information shall include thickness of <br />Mixed "). Please delete the extraneous sentence fragment. <br />The extraneous sentence fragment has been removed. <br />b. The Division requested several clarifications to amended Subsection 15.0 "Topsoil <br />Remediation Plans ". Updated narrative was provided, but several wording changes are still <br />warranted. In the first sentence of the subsection, "spoil" should be "soil'. In the last <br />sentence of Item 3 of the enumerated remediation plan, reference in parentheses to the <br />original grid should state "(1 hole per 2.5 acres on prime farmland, I hole per 5 acres on non- <br />prime farmland) ", to correspond with amended Tables (d) -lA and (d) -1B. In the next to last <br />paragraph of Subsection 15.0, the third sentence refers to calculation of a "weighted <br />average ". The procedure described would appear to involve calculation of a simple average, <br />not a weighted average. Please amend the text as warranted. <br />The text error of "spoil" has been corrected. The average is a simple average and is now <br />referred to as such. <br />78F. This item addressed modifications to Tables (d) -lA and (d) -1B. These issues have been <br />incorporated into Item 76A, above. As a result, the Division considers this item to be resolved. <br />Resolved. <br />79. This item addressed modifications to Tables (d) -IA and (d) -IB. These issues have been <br />incorporated into Item 76A, above. As a result, the Division considers this item to be resolved. <br />Resolved. <br />80A. Resolved. <br />80B. In this item, the Division requested commitment regarding follow -up sampling and remediation <br />associated with Bench 1 Sample Site #32, to be performed prior to topsoil replacement. Two <br />previous sample analyses had indicated EC levels slightly above 7.0 mmhos /cm, in exceedance <br />of the 6.0 threshold criteria for Bench 1 subsoil substitute material. In response, WFC stated that <br />the location was sampled once again, in July 2010, with an EC result of 3.98 mmhos/cm, which <br />is below the applicable threshold, and which WFC concludes is sufficient to demonstrate that no <br />further testing or remediation is warranted for the location. Amended narrative in Subsection <br />16.0 describes the Sample Site #32 EC results, and references the July 2010 testing by Walsh <br />Environmental (analytical results provided in amended Attachment 2.05.4(2)(d) -1). The <br />Division is not convinced that two samples showing EC levels above 7.0, and 1 sample with EC <br />result of 3.98, for the same sample location, would be adequate to demonstrate that material in <br />the vicinity of Site #32 is suitable for subsoil substitute. <br />
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