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3. Analytical data associated with Wadge overburden and immediate underburden are <br /> presented in Tables 6-4 through 6-7, and Appendices 6-3 and 6-4 of Tab 6. Analytical <br /> data associated with Wolf Creek and Sage Creek overburden and underburden are <br /> presented in Tables 6-7A through 6-71), and Appendix 6-3 of Tab 6. Summary Tables <br /> and text delineating unsuitable zones and addressing mitigative measures for unsuitable <br /> zones within Wadge, Wolf Creek and Sage Creek overburden and underburden are <br /> included in Appendix 6-5. <br /> Wadge Overburden/Underburden Assessment <br /> In 4% or less of the samples analyzed, pH, acid/base potential, boron, manganese, <br /> cadmium and zinc exceeded suspect levels. In general, the Division concurs with the <br /> applicant's determination that normal mixing of overburden will mitigate the toxic effects <br /> of these materials. D.J. Dollhopf, in Selective Placement of Strip Mine Overburden in <br /> Montana(Chapter 5, Summary Report, 1981) suggests that when the volume of toxic <br /> material is less than 15% of total volume to be replaced, dilution of the toxic material <br /> can be successful. <br /> Two primary concerns identified by the Division as a part of the PR1 review regarded <br /> potentially acid forming materials associated with the Lennox coal seam and excessive <br /> clay contents associated with shale strata overlying the Lennox. The Division requested <br /> that SCC prepare spoil sampling and mitigation plans for areas where the Lennox <br /> would be spoiled or,would potentially be exposed by high wall reduction. The Division <br /> also requested a detailed mitigation plan for areas of excessive clay. SCC submitted an <br /> acceptable sampling plan for areas potentially affected by Lennox spoil or outcrop within <br /> the original permit area. <br /> The plan specified taking samples on 500 foot centers within the designated area, and <br /> analyzed for clay content, pH, and acid-base potential. Mitigation included additional <br /> sampling to define the area of concern, deep ripping of areas of unsuitable clay content, <br /> and amendment or burial of acid-forming material with a minimum of four feet of <br /> suitable material as cover. The regraded areas were sampled during reclamation as <br /> required, and all of the samples indicated no mitigation would be required. <br /> Nitrate/nitrogen levels were excessive in 14%of the overburden core samples taken at the <br /> Seneca IIW Mine. The locations of the holes exhibiting elevated levels were distant from <br /> one another. Furthermore, the stratigraphic locations of elevated nitrate/nitrogen samples <br /> are not correlative. Due to the vertical and horizontal distances between locations with <br /> elevated nitrate/nitrogen levels,percolating ground water will not be adversely affected. <br /> The dilutional effects of a predicted spoils aquifer should buffer the concentration of <br /> nitrate as nitrogen by the time the aquifer discharges to the surface system. <br /> Wolf Creek/Sage Creek Overburden/Underburden Assessment <br /> Only two parameters (iron and lead)exhibited unsuitable levels within sampled <br /> increments from the one bore hole that penetrated the sequence in the south extension area. <br /> Within each of four delineated intervals (Sage Creek, Upper Wolf Creek, and Lower Wolf <br /> Creek overburdens, and Wolf Creek underburden),composite samples were taken from <br /> each 10 foot depth increment. The average value for lead within the Lower Wolf Creek <br /> overburden interval was in the unsuitable range, due to a very high value within one of <br /> five sampled increments. One or more sample increments within the Sage Creek and <br /> Wolf Creek overburden intervals exhibited unsuitable iron levels, but the average iron <br /> level within each interval was suitable. One of six sampled increments in the Upper <br /> Wolf Creek overburden was in the unsuitable range for lead,but the average value for the <br /> Page 17 of 37 <br />