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C-1981-008 - SL-12 <br />Adequacy Review No. 4 <br />5 May 2011 <br />Page 10 of 10 <br />may avoid some confusion later. The final "C" factor of.0299 was obtained by subtracting .000936 from.03. <br />It appears, however, that .000936 should be subtracted from .031, resulting in a value of .030064. If you <br />agree, please revise page 23 accordingly. If you do not agree, please explain. <br />WFC revised the methodology concerning the alfalfa cover in the March 31, 2011 response. This cover <br />factor calculation is no longer needed. Item resolved. <br />4. On page 23, there is a sentence that states that the actual canopy is 45.7%. As stated earlier in the same <br />paragraph, however, it appears that this value should be 23.4%. Please revise accordingly. <br />WFC revised the methodology concerning the alfalfa cover in the March 31, 2011 response. This statement <br />no longer appears in the revised page. Item resolved. <br />5. The Division understands that Western Fuels will reconsider its methodology in calculating the soil loss <br />comparison as it relates to the alfalfa cover. <br />VY'FC revised its methodology in the calculation of the cover factor so that all of the alfalfa is included as <br />cover with no canopy component. Item resolved. <br />Based on the results of the Division's review, we will not be in a position to approve the Phase III portions of the <br />bond release application for Irrigated Pasture. The dryland pasture does successfully achieve the Phase III <br />criteria. If WFC satisfactorily addresses the remaining Phase II issues on topsoil, the Division will be able to <br />propose a Phase II release. A meeting is scheduled for Friday May 13, 2011 with the Division and Greg Lewicki <br />and Associates to discuss the SL-12 application. Please let me know if representatives of Western Fuels Colorado <br />also want to participate. We will set up a conference phone if you prefer to participate by phone. <br />Sincerely, <br />,4? ?? 6,? <br />Sandra L. Brown <br />Sr. Environmental Protection Specialist <br />cc: Greg Lewicki and Associates <br />Marcia Talvitie, DRMS