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referenced in current literature and guidelines developed by various western state <br />regulatory agencies. For example, Wyoming guidelines list pH values of 5.0 to <br />5.5, EC levels of 8 to 12, SAR levels of 10 to 12, and selenium levels of 0.3 to 0.8 <br />as marginal, and boron levels in excess of 5.0 ppm as unsuitable. We would <br />suggest that similaz suspect levels would be applicable for Colowyo, unless <br />documentation supporting alternative suspect levels is provided. <br />Please review the current parameter list suspect levels and amend as <br />appropriate. <br />1 I. Colowyo has an ongoing topsoil stripping, replacement and stockpiling operation <br />in advance of the current West Pit and for reclamation of the East Pit. Some of <br />the topsoil is live hauled to regraded spoils but much of the topsoil is stockpiled. <br />Over the summer a large azea was stripped in advance of the West Pit and the <br />topsoil was placed in existing topsoil stockpile 15B. This is similaz to what <br />happens every yeaz at the Colowyo Mine. There is no data, however, in the <br />Annual Reclamation Report(s) that details how much topsoil was stripped, where <br />it was stripped, where it was placed (either live-hauled or what stockpile it was <br />placed in) or what azeas were exempted from topsoil stripping due to soil <br />conditions (and how these areas relate to the soil mapping units). <br />Please include a description and table of yearly topsoil removal, stockpiling <br />and replacement along with text explaining how Colowyo determines the <br />topsoil volumes removed, stockpiled and replaced as well as information on <br />how Colowyo determines overall topsoil stockpile volumes. Please include <br />this information for each year forward in the Annual Reclamation Report <br />(beginning with the 2005 ARR) including stripping areas, volumes stripped, <br />volumes stockpiled and where they were stockpiled, volumes live handled <br />aad areas that have been exempted from topsoil removal. Please include a <br />map of these areas as well. <br />This concludes the adequacy review for CCC's Technical Revision 62. Please contact <br />me at (303) 866-4929 if you have any questions or concerns regazding this adequacy <br />letter. <br />Sincerely, <br />James R. Stark <br />Environmental Protection Specialist <br />