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<br /> <br /> C, 7C7 r,G n ,i :.2 C) 1 F1C .'00"1 ~ . r.4 <br /> f <br /> <br /> <br /> <br /> Mr. Kent Lucien <br /> Mr. Jere Henderson <br /> 1 1., z7 °0~ <br /> V4Yf <br /> Page 2 <br /> your proposal were required for us to complete our assessment and make a final <br /> wo.ormSnaticn. Although this initial inadko ing and Reuse Tian was submitted in a timely <br /> manner, the department found that the plan lacked Information required to make a <br /> determination about your proposal. We requested specific details about your proposal In <br /> meetings Atilt conversations with your representatkes as wet} ass In our ;.anua^, 2fs and <br /> March 12, 200400 letters. However, details about your plan were rot provided until this recant <br /> sukalussNNi re4eived June 6, 2004. it should also be noted that this submission continues <br /> to exclude items previously requested by the department. <br /> Tha rienartment han rawlaum i v'-ur MurPatin snrl ta,n..o Plan ft-d,- <br /> _y v.., g +m w , vvw4 . ,sa. I to Idorsta ,da at ifl <br /> diwrNnwdlw s{.... <br /> fallawirtg: <br /> 1. The growing area will consist of an 18-Inch thick subbase of ashlsoif blend, coverI <br /> an area of approximately 20 acres. <br /> 2. The ground underlying this 18-Inch thick growing area will consist of compacted coal <br /> asn to brio the area to proper grade, or soil harvested from the surrounding <br /> oroporty N insufficient ash is nresant. <br /> 'v A grading plans gas rV% bale's consplated. <br /> 4. The growing area will be covered 6-12 inches of top soil. Soil will be excavated from <br /> surinundIng AreAr to serve as tors sell- <br /> - . I he plait iso ititi9w pii>pi/ k rousing the site in sections, but proposes to regrade, <br /> the entire area at once. <br /> 61 The growing are„aa will utilize alt Of Lhe .:;;h currently at the site, whin Is <br /> apprximatly 500,000 cubic yards (coat ash and soil), <br /> 7. The plan continues to exclude the use of test clots; as nrininnliv aara_arf In <br /> conversations with your staff. <br /> Based on our review of your plan, your proposal does not meet the definition of recycling- <br /> I no plan indicates that compacteq coal ash and soil will be used as fill below the growing <br /> subbase. Based on the assumntinn that alt Ann Mxt tY iihic yards of ash and soil will be .u3-1 <br /> for the growing area, the department estimates that an average depth of 14 feet of coal ash <br /> N d.w: 'll L... ..I...,....J.....1..-ai... i t_..~. w.'f-tom ` p.a_ <br /> a+iu o0,; w;„ uo pj. a u, nm, c, ro r 8-n n:n subbase. T, ni2i average ils itt i8 expected t0 be <br /> greater as it assumes that no soil will be added to the 1 e-inch subbase. <br /> $Inrw n nrartinn nfan hgc not hasp prepared, " yo.v v s+ur..d. are Nan ONe to „ timato and i.,na w. a6 <br /> t.,o <br /> ,yny <br /> need for fill for your proposed activtty.. Therefore, the ash does not appear to serve a <br /> utwefty" puipuse. in addition, the its-inch thick oubba86%top soil cover appears to <br /> function as a cap to the buried coal ash. As Presented, vour oro~-SAl in r_.nncirlargri a <br /> special waste landfill and an associated solid waste management permit will be required. <br /> n ~Nv ja e^s c.'vfv° ic:rdfiii 1;vrii % appi'si.8tiajn iw if Uov IV) yvuf Ube. <br /> f'tiox a ssessment <br /> The department perfonned a cursory review of your risk assessment. The department <br /> uVes IIV% IntGt id lv W 1z3i rcjn the I6aOthietu liiiiit8 in tVM currOiit PWMR. <br />