2011-10-14_REVISION - C1981008 (5)

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C- 1981 -008 Oct. 14, 2011 TR -61 PAR Page 2 of 3 comments directly to the OSM; these comments were incorporated into the October 14, 2011 review letter from OSM, which is attached. The Division has received one objection, to date from JoEllen Turner, by facsimile on October 11, 2011. (This document was previously transmitted via E -mail to WFC on October 12, 2011 by the Division.) A printed copy is attached to this letter. The OSM letter identifies several issues regarding the proposed soil sampling plan. OSM is also asking WFC to provide the soil suitability criteria. To address this question, the Division first requests that WFC evaluate the prime farmland suitability soil and spoil criteria (Morgan Prime Farmland) approved in Table 2.05.4(2)(d) -1A to determine if the criteria will achieve the requirements of Rules 2.06.6 and 4.25. This assessment needs to be done with full consideration of the technical recommendations made by OSM with their previous oversight reports dated August 1, 2011. Second, the Division recognizes that a complete evaluation of soil suitability will not be possible until the field samples have been collected and the chemical and physical properties are analyzed. The full evaluation of the suitability of the soil materials to achieve the prime farmland standards will be conducted after the samples have been collected and the sample analysis is complete. The Division has conducted a Preliminary Adequacy Review (PAR) of the TR -61 application. 1. Section 2.04.9 — Subsection 18 a) Subsection 18 has been entitled, "2011 Topsoil and Stockpile Sampling Program ". In order to be consistent in the terminology used, please revise the title of Subsection 18 to read as follows: "2011 Soil Sampling and Analysis Plan ", and revise the Table of Contents accordingly. b) In the first paragraph of Subsection 18, please revise the second line to read, "...WFC has contracted Key Agricultural Services, Inc. (Key -Ag) to prepare and conduct a sampling and analysis plan for the ..." c) Please modify the second paragraph of Subsection 18 to read as follows: "The Sampling and Analysis Plan (SAP) prepared by Key -Ag can be found in Attachment 2.04.9 -10." 2. Attachment 2.04.9 -10 a) Attachment 2.04.9 -10 has been entitled, "2011 Stockpiled Soil Sampling Plan ". In order to be consistent in the terminology used, please revise the title of this Attachment to read as follows: "2011 Soil Sampling and Analysis Plan ", and revise the Table of Contents accordingly. b) Introductory text is provided on page 2 of this attachment. Please title this page, "Introduction ". c) Please consider revising the first paragraph to read as follows: "In a letter dated August 8, 2011, the Colorado Division of Reclamation, Mining and Safety (DRMS) required WFC to develop a sampling and analysis plan for soil stockpiles and undisturbed soils on the Morgan property. The following Sampling and Analysis Plan (SAP), has been developed by Key Agricultural Services, Inc. (Key -Ag) and WFC, in consultation with the NRCS, OSM, and DRMS, and is intended to satisfy the requirements of that letter. d) Please consider revising the second paragraph of the Introduction to read as follows: "This attachment contains the Sampling and Analysis Plan and a map of the proposed sampling locations (Map 2.04.9 -3). Field data and analytical results will be incorporated at a later date, when such results become available.