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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
Metadata
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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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Rule 2.04.9 Soils Resource Information <br />4B. a. As requested, a current version of the NSSH Chapter 657.5 (please provide a notation that <br />this version has an effective date of January 1, 2000), which provides the NRCS criteria for <br />prime farmlands, was provided as revised Attachment 2.04.94. However, a previous version <br />of NSSH Chapter 657.5 was (apparently erroneously) included at the very end of Attachment <br />2.04.9 -3 ( "Taxonomic Unit Descriptions "). Please address this apparent error and remove <br />the version of Chapter 657.5 from Attachment 2.04.9 -3 as warranted. <br />Notation was added to the current NSSH Chapter 657.5 in Attachment 2.04.94. The <br />previous version has been removed from Attachment 2.04.9 -3 <br />In addition, the Division had requested the operator to include a cautionary statement, noting <br />that any outdated documents included as attachments are being included in the permit <br />package for historical reference only. One such outdated document is included as <br />Attachment 2.04.9 -5. In the table of contents listing of attachments for Section 2.04.9, the <br />cautionary statement is included but is improperly written as two sentences rather than a <br />single sentence... "Contains erroneous data and should be used. For Historical purposes <br />only." This same improperly worded statement is included as a notation on the cover sheet <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 />Cautionary notation added to both the TOC and Attachment 2.04.9 -5. <br />b. The Division had requested text reference to certain NRCS documentation addressing <br />erroneous information regarding prime farmland criteria. The requested reference was <br />provided. Item 413(b) Resolved <br />4C. This item was incorporated in Item 14 of the 7/23/10 adequacy letter. <br />See Item 14. <br />4D. This item requested additional explanation regarding NRCS letter of October 14, 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 21 acre area of D70B <br />(Bari Scalped/Barx Buried Complex) soil within the area (as mapped by Peabody), or solely to a <br />1.19 acre area of Unit 15 (Bari) soil in the extreme SE comer 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 <br />and 1998 ", WFC references the current version of National Soil Survey Handbook <br />(NSSH) Chapter 657.5 prime farmland criteria. At the end of the sentence, it is indicated <br />that the criteria are "for the initial permit'. The current 657.5 criteria, dated January 1, <br />2000, would apply to the entire permit area, notjust the initial permit. Please delete the <br />clause "for the initial permit' at the end of the 1" sentence of subsection 10.1. <br />Clause "for the initial permit' deleted. <br />
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