APPCOR10134

• Permit No: C1994082
• IBM Index Class Name: Application Correspondence
• Doc Date: 1/20/1995
• Doc Name: YOAST MINE C-94-082 PERMIT APPLICATION
• From: DMG
• To: SENECA COAL CO PEABODY WESTERN COAL CO
• Media Type: D
• Archive: No

of these roads without proper documentation. Please provide the necessary information
for road retention, or revise the table to omit the redistribution exclusion.
74. Table S lists suitability criteria for overburden, underburden, and regraded spoils. There
appeaz to be discrepancies between three of the criteria in this table and guidelines
currently available from other Rocky Mountain states and the USDI-OSM. In the
absence of published criteria for Colorado, the Division recommends general adherence
to criteria established in these publications. Three publications relevant to pH, Se, and
Mo criteria aze:
- Montana Department of State Lands Reclamation Division, 1994, Soil,
Overburden and Regraded Spoil Guidelines, 32p.
- Wyoming DEQ, 1984, Guidelines No. 1, Topsoil and Overburden, 34p.
- USDI/OSM, 1991, Overburden Sampling and Analytical Quality Assurance and
Quality Control (QA/QC) Requirements for Soils, Overburden,.and Regraded
Spoil Characterization and Monitoring Programs for Federal Lands m the
Southwestern United States, 22p. This is apparently a revised version of.the 1985
USDI/OSM document reference in the permit application package.)
The discrepancies mentioned above aze:
a. Tab 6 proposes an unsuitability criterion of less than 4.5 for pH. The MDSL and
USDI guidelines recommend an unsuitability level of less than 5.5. The WDEQ
recommends a level less than 5.0 as unsuitable. Please incorporate one of these
criterion into Tab 6, or explain the justification for the 4.5 pH unsuitability
criterion.
b. Tab 6 proposes an unsuitability criterion of greater than 0.5 ppm for Se. SCC
apparently used an extractable Se analysis, based on reference to a Soltanpour and
Schwab method. MDSL and WDEQ guidelines suggest an unsuitable or suspect
level of 0.1 ppm. USDI suggests an unsuttability level of greater than 0.15 ppm
for the southwestern U.S. t is not cleaz how the results from SCCs analysis
correlate with hot water extraction methods recommended by USDI and MDSL
guidelines (Pale, A.L(ed),1982, Methods of Soil Analysis, Agronomy Monograph
o. 9, Amencan Society of Agronomy). Please explam how CCs results
correlate with the USDI Publication referenced in Tab 6 and revise or justify the
proposed unsuitability cntenon as appropriate.
c. Tab 6 proposes an unsuitability criterion of greater than 2.0-8.0 ppm for Mo.
MDSL and WDEQ guidelines suggest a suspect level of 1.0 pm. Tab 6
references a 1987 Peabody publication which the Division does not have available
for review. Please revise the criterion in Tab 6 in accordance with the guidelines
above and/or provide a copy of the 1987 Peabody publication and any necessary
justification for the proposed Mo criterion.
If changes to any of the unsuitability criteria discussed above aze revised in the permit
application package, Appendix 6-3 will also need to be revised to reflect those changes.
Tab 22 - Revegetation Plan
75. Page 7 references retention of Roads A and B. As noted in previous comments above,
this language cannot be approved in the permit application without proper
M. Allavilla and G. Wendt 13 January ]3, 1995