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• Within the replaced growth medium of the reclaimed prime farmland, approval of <br />PR -6 allowed an increase in EC from a maximum of 4 mmhos/cm, to a maximum <br />EC of 6 mmhos /cm. Such an increase in EC has strong potential to accept reclaimed <br />soils that may be toxic to corn as well as have a detrimental impact on alfalfa <br />production. Considering that alfalfa is the target crop for demonstrating the yield <br />capability of the reclaimed prime farmland and that corn is likely to be a primary <br />rotational crop after the land is returned to the landowner, approval of an EC <br />threshold of 6 mmhos/cm for affirming the suitability of the growth media to be <br />used for reclamation is not in compliance with the regulations at 4.05.8(1), 2.06.6 (2) <br />(d), and 4.06.2 (4) (a) of the Colorado State Program. <br />• The sampling methods described in the permit for confirming the suitability of the <br />soil/overburden substitute materials approved for use in reclaiming prime <br />farmlands, do not reflect common industry practice, are not representative of <br />sound scientific procedure, and are therefore not in compliance with State Program <br />regulation requirements at 4.05.8(1) and 2.06.6(4)(c). OSM's review fmds the <br />content of some of the statements made relative to sampling, confusing; and finds <br />such language within the permit to not be in accord with the obligation that the . <br />permit be written in a clear and concise manner as required in the Colorado State <br />Program regulations at 2.03.3 <br />5. REVIEW PREPARED BY: <br />c o?„, <br />A M Gregor, Soil Scientist Date <br />Rick Williamson, Ecologist & Technical Team Leader <br />22 <br />- 7/is - JO <br />?- <br />Date <br />