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conditions are expected to be avoided by dilution or burial. However, the narrative <br />further acknowledges the potential that areas of unsuitable material could be <br />deposited at the surface of the graded spoils. The Division concurs with these <br />determinations, and finds the regraded spoil sampling and mitigation plan as <br />referenced on page 40, Tab 6, to be warranted and appropriate. The sampling plan <br />was applied to all regraded spoil areas and graded final high walls in the south <br />extension mining block (both Wadge and Wolf Creek/Sage Creek mining areas). As <br />previously mentioned, the monitoring conducted during reclamation indicated all <br />spoil materials sampled were suitable. <br />Pursuant to 4.05.8(3), temporary storage of acid-forming or toxic -forming spoil may <br />exceed 30 days if the operator demonstrates that burial or treatment is not feasible <br />within 30 days due to weather conditions or other specified factors, and will not <br />result in material risk of water pollution or other environmental damage. If deemed <br />necessary by the Division based on the quantity, location, and chemical <br />characteristics of any temporarily stored acid-forming or toxic -forming spoil, such <br />spoil shall be placed on impermeable material. <br />Based on data included in annual reclamation reports, spoils exhibiting acid-forming <br />or toxic -forming potential or other chemical unsuitability have not been replaced on <br />the surface. A very low percentage of samples (primarily final high wall locations) <br />have indicated excessive clay content. Such high clay areas are ripped during <br />regrading operations to relieve compaction. No indication of the presence of acid- <br />forming or otherwise deleterious regraded spoil has been found by the Division <br />during mine inspections. <br />Based on the baseline data and assessment provided in the permit application, <br />monitoring commitments described for both the Wadge and Wolf Creek/Sage Creek <br />spoils, and monitoring results and observations to date, the operation is in <br />compliance with performance standards related to acid-forming and toxic -forming <br />spoil. <br />E. Impoundments: This section was discussed above in Section C. <br />F. Surface and Ground Water Monitoring <br />C'.rrnmrl Water <br />Tab 7 of the permit application contains baseline ground water hydrology <br />information. Section 7.1 contains the baseline information for the original permit <br />area, while Section 7.2 contains updated information for the Seneca II -W South <br />Extension Area. The ground water information section of the application was most <br />recently updated in 2002 in association with Permit Revision No. 3 (PR -3). Tab 15 <br />describes the operational ground water monitoring program. The current hydrologic <br />monitoring program is presented in Appendix 15-3a of the permit application <br />package, updated in association with TR -63 in 2009 and TR -69 in 2010. Monitoring <br />11 <br />