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Accordingly, the data collected from this proposed sampling study will need to be considered in <br />concert with previously collected data from this site, to create new suitability threshold <br />requirements for both the salvaged soils as well as all soil substitutes, on the Morgan property. <br />The previously collected data would include the baseline data from the prior Peabody permit and <br />the baseline data that is currently included within the approved permit. The development of <br />appropriate soil /soil substitute criteria is necessary as a measure to determine the capability of <br />the salvaged soils and soil substitutes for restoring the original prime farmland soil productive <br />capacity. New soil and soil substitute criteria must be developed in consultation with the <br />Natural Resources Conservation Service (MRCS) and must adhere to the guidelines established <br />in Federal Register Notice 99- 16470. These guidelines state that the pH and other chemical <br />properties of the major horizon of the reconstructed soil, must be within the ranges of the <br />premined soil or be more favorable for plant growth. In short, the new suitability criteria will <br />likely need to be similar to the characteristics of the prime farmland soils that existed on the <br />Morgan property prior to mining. <br />In summary, the sampling/analysis plan included within the permit revision application <br />submitted by WFC is missing key details. The provision of additional information addressing <br />these details would enable OSM to determine if the proposed sampling plan is adequate and is in <br />compliance with state regulations at 2.06, 4.05.8, and 4.25. <br />Should you have any questions related to the issues discussed above, please contact me by phone <br />at 303 - 293 -5047, or via email at rlwilliamson(a,OSMRE.gov <br />Sincerely, <br />Avg[ W , <br />Rick Williamson <br />Manager, Indian Programs Branch <br />Cc: Steve Park, State Soil Scientist, NRCS <br />