Laserfiche WebLink
D <br />Mr. Zach Trujillo <br />December 17, 2015 <br />Page 8 <br />Response: A response to this comment was submitted on November 20, 2015. <br />ITEM 70. Of the six drill holes that were sampled for overburden/interburden analysis, only <br />one falls within the 1.4 square mile (approximate) footprint of the newly proposed Collom pit (C- <br />04-25). The guidelines call for a minimum of three sampling locations with a spacing of <br />approximately one hole per square mile (from reference I below). In the geochemical analysis, <br />CCC has also cited a guideline published by the Wyoming Department of Environmental Quality <br />(from reference 2 below), which calls for an initial sample spacing of one hole per 80 acres <br />(which is equivalent to eight holes per square mile). <br />The geochemical data from the six holes is presented in Exhibit 6, Item 9, and summarized in <br />table 2.04.6-7 and in the text. The data shows that hole C-04-25 contains a greater proportion of <br />unsuitable overburden material than the other five holes. For example: <br />• A significant proportion of the overburden sampled at this point (27%) contains <br />Molybdenum at greater than 1 ppm. <br />• The deeper horizons are notably high in Arsenic, with a maximum value of 39.8 ppm <br />(compared to the WY DEQ criteria of <2.0 ppm). <br />• The deeper horizons also have elevated levels of Sodium, as indicated by the high SAR <br />values. <br />In summary, the data provided are not sufficient to adequately characterize the material that will <br />be disturbed by the proposed Collom pit. The analysis, as currently presented, underestimates <br />the proportion of material that fails to meet the suitability criteria. <br />a. Please revise table 2.04.6-5 to better reflect the content of the Wyoming DEQ reference <br />cited. <br />b. Please present additional data that will allow more adequate characterization of the <br />overburden material in the Collom pit; pursuant to rule 2.04.6(2) (b) (ii) the Division suggests <br />an initial spacing of one hole per 80 acres. <br />c. Please revise Exhibit 6, Item 9; Tables 2.04.6-6 and -7; and the text of Volume 15, Rule 2, <br />Pages 15-18 accordingly. <br />d. In the process of addressing items b. and c., please be specific about which horizons will be <br />handled selectively and how that will be accomplished. <br />Response: A response for this comment will be submitted at a later date under a separate cover <br />letter. <br />ITEM 71. In volume 1, some of the footer information gives the permitting action revising those <br />pages as PR -06. Please change the footer to refer to PR -04 throughout. <br />Response: A response to this comment was submitted on November 20, 2015. <br />A Tmch.,,tonr Energ; l'onperittvti <br />