Laserfiche WebLink
<br />3 <br /> <br />b. Wyoming DEQ, 1984, Guidelines No. 1, Topsoil and Overburden, 34p. <br />c. USDI/OSM , 1991, Overburden Sampling and Analytical Quality Assurance <br />and Quality Control (QA/QC) Requirements for Soils, Overburden, and Regraded Spoil <br />Characterization and Monitoring Programs for Federal Lands in the Southwestern United <br />States, 22p. (This is appazently a revised version of the 1985 USDI/OSM documnet <br />referenced in the PAP.) <br />The discrepancies mentioned above are, <br />A. Tab 6 proposes an unsuitability criterion of less than 4.5 for pH. The MDSL <br />and USDI guidelines recommend an unsuitability level of less than 5.5. The WDEQ <br />recommends a level less than 5.0 as unsuitable. Please incorporate one of these criterion <br />into Tab 6, or explain the justification for the 4.5 pH unsuitability criterion. <br />B. Tab 6 proposes an unsuitability criterion of greater than 0.5 ppm for Se. SCC <br />appazently used an extractable Se analysis, based on reference to a Soltanpour and Schwab <br />method. MDSL and WDEQ guidelines suggest an unsuitable or suspect level of 0.1 ppm. <br />USDI suggests an unsuitability level of greater than 0.15 ppm for the southwestern U.S. It <br />is not cleaz how the results from SCCs analysis correlate with hot water extraction methods <br />recommended by USDI and MDSL guidelines (Page, A.L.(ed), 1982, Methods of Soil <br />Analysis, Agronomy Monograph No. 9, American Society of Agronomy). Please explain how <br />SCC's results correlate with the USDI publication referenced in Tab 6 and revise or justify <br />the proposed unsuitability criterion as appropriate. <br />C. Tab 6 proposes an unsuitability criterion of greater than 2.0-8.0 ppm for Mo. <br />MDSL and WDEQ guidelines suggest a suspect level of 1.0 ppm. Tab 6 references a 1987 <br />Peabody publication which the Division does not have available for review. Please revise <br />the criterion in Tab 6 in accordance with the guidelines above and/or provide a copy of the <br />1987 Peabody publication and any necessary justification for the proposed Mo criterion. <br />If changes to any of the unsuitabilility criteria discussed above are revised in the PAP, <br />Appendix 6-3 will need to be revised to reflect those changes. <br />3. In Tab 6, SCC proposes to sample regraded spoil at 500 foot centers offset at 60 <br />degrees. If the Division interprets this correctly, the sampling pattern would allow for <br />interpolation based on a 250 foot radius around each hole. Regraded spoil at the Seneca <br />II Mine is sampled on a 300 foot grid, which results in a 225 foot radius for interpolation. <br />Since the Wolf Creek overburden at both sites is similaz, and since roughly ten percent of <br />the regazded spoil sampled at the Seneca II Wolf Creek pit showed potential acid problems <br />in 1991, the Division recommends sampling regraded spoil at the Yoast Mine in a pattern <br />with a radius equal to or lesser than that used at the Seneca II Mine. Please revise this <br />section accordingly. <br />