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interval was marginally suitable. Concern relative to elevated levels of the two metals are <br /> minimized due to the neutral to slightly basic pH range indicated within each sampled <br /> increment, and the resulting low solubility of the metals. <br /> Sampling of the Wadge underburden/Sage Creek overburden at the adjacent Yoast Mine <br /> permit area identified no unsuitable parameter levels; however, a concern was identified <br /> regarding potential acidity in the Wolf Creek overburden, particularly in a zone 20 to 35 <br /> feet above the coal seam. Narrative in Tab 21 of the Yoast Mine permit application <br /> discusses this zone,the spoil monitoring program employed and the mitigation by burial <br /> with a minimum of three feet of suitable material prior to soil replacement. <br /> The Division concurred with these determinations, and finds the regraded spoil sampling <br /> and mitigation plan as referenced on page 40, Tab 6, warranted and appropriate. As <br /> previously mentioned,the monitoring conducted during reclamation indicated all spoil <br /> 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 result <br /> in material risk of water pollution or other environmental damage. If deemed necessary <br /> by the Division based on the quantity, location, and chemical characteristics of any <br /> temporarily stored acid or toxic forming spoil, such spoil shall be placed on impermeable <br /> material. <br /> Based on data included in annual reclamation reports, spoils exhibiting acid or toxic <br /> forming potential or other chemical unsuitability have not been replaced on the surface. <br /> No indication of the presence of acid forming or otherwise deleterious regraded spoil has <br /> been found by the Division during mine inspections. <br /> Based on the baseline data and assessment provided in the permit application,monitoring <br /> commitments described for both the Wadge and Wolf Creek/Sage Creek spoils, and <br /> monitoring results and observations to date, the operation is in compliance with <br /> performance standards related to acid forming and toxic-forming spoil. <br /> E. Surface and Ground Water Monitoring <br /> Ground Water <br /> Tab 7 of the permit application contains baseline ground water hydrology information and <br /> describes the characteristics of the various aquifers. Section 7.1 contains the baseline <br /> information for the original permit area, while Section 7.2 contains updated information <br /> for the Seneca IIW South Extension Area. The ground water information section of the <br /> application was most recently updated in 2002 in association with Permit Revision No. 3 <br /> (PR3). Tab 15 describes the operational ground water monitoring program. The current <br /> hydrologic monitoring program is presented in Appendix 15-3a of the permit application <br /> package, updated in association with TR63 in 2009, TR69 in 2010 and TR82 in 2016. <br /> Monitoring locations are shown on Exhibits 7-1 (for the original permit area) and 74A <br /> (for the South Extension Area). <br /> The monitoring program consists of 15 groundwater sites. Ground water points of <br /> compliance have been established and are referenced in Appendix 15-3b. The standards are <br /> applied to Dry Creek Alluvial Well DCAL-02. The current monitoring plan requires <br /> monitoring of water quality and/or water levels at specified intervals as per permit section <br /> Page 18 of 37 <br />