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i. <br />• • <br />In summary, Wyoming Fuel Company believes that given the <br />initial premises described above, the alledged "inconsistencies" <br />referred to in the Apparent Completeness Review serve no useful <br />function towards achieving the goal of understanding the general <br />stratigraphy within the area to be mined. Also, because only 2 <br />of the 7 holes referred to fall within the actual pit limits (the <br />remaining 5 holes lie within or south of the fzulted area south <br />of Pit 1), meticulous dissection of individual lithologies for the <br />remaining 5 holes clearly serves no useful purpose in determining <br />the mineability or reclamation potential of Pit 1 or Pit 2. <br />2.04.6(1) (b) (i) (B) <br />Refer to comments under 2.04.6(1)(a)(i) above. <br />2.04.6(1) (b) (i) (C) <br />An "average compaction factor" was not calculated by Wyoming <br />Fuel Company. Instead, a swell factor of 20 percent was calculated <br />for backfilled overburden based on relative volume changes between <br />air photos dated May 15, 1978 and August 29, 1979. Exhibit 2 <br />is an interoffice memo from Robert Green to Mike Ko1in of Wyoming <br />Fuel Company which more specifically explains this calculation. <br />Exhibit 2 also includes copies of the two topographic maps used. <br />As indicated in the Apparent Completeness Review, Wyoming Fuel <br />Company does not "presume" that uncompacted spoil swells by approxi- <br />mately 15 percent. The overburden stockpile is well compacted both <br />because it was constructed in shallow scraper lifts and because it <br />has settled for over 5 years. Wyoming Fuel Company believes that it <br />is reasonable for in situ overburden material to swell more than <br />compacted overburden stockpile material; that is, some swell already <br />exists in the stockpile material. <br />2.09.6(1) (b) (i) (D) <br />Nature has dictated the anomalously high sodium absorption <br />ratios exhibited by much of the overburden (particularly in the <br />vicinity of the nose of the anticline) not S~7yoming Fuel Company. <br />The fact that the sodium absorption ratio is many times greater <br />than the maximum unsuitable by Wyoming DEQ Guidelines is only <br />important if the overburden is to be left at the surface (i.e., as <br />a topsoil substitute). The regulatory authority is directed to the <br />completion of the reference quoted on Page 48 of Appendix C which <br />states "Wyoming Fuel Company does not intend to utilize any of the <br />overburden as a substitute for topsoil". <br />-2- <br />