1987-02-25_REVISION - C1981012 ‎(3)‎

• Permit No: C1981012
• IBM Index Class Name: Revision
• Doc Date: 2/25/1987
• Doc Name: Letter
• From: MLRD
• To: WYOMING FUEL CO
• Type & Sequence: TR8
• Media Type: D
• Archive: No

l1
STATE OF COLORADO
Roy Romer, Govei
DEPARTMENT OF NATURAL RESOURCES
MINED LAND RECLAMATION DIVISION
DAVID C. SHEITON, Director
DATE: April 1, 1987
T0: Jim Stevens
FROM: Jeff Deckler '~
RE: New Elk Mine, Technical Revision 08 -File No. C-81-012
I have completed my review of the additional soil sampling submitted by WFC to
fulfill Stipulation 19. This review identified several problems, as follows:
In comparing the sample results of July, 1985, with results from
adjacent holes sampled in December 1986, it is evident that there is no
correlation between the data. There are consistently large
discrepancies in texture, pH, and SAR between adjacent holes in the two
sample populations. This casts doubt on the validity of the data.
In the area between the oil house and the No. 1 Warehouse, sample
results (Nos. 6, 7, 8, 9, 14, 15 and 16) indicate potential problems
with SAR and pH. WFC's comment on page 2.04-40(A) that these problems
will be mitigated by topsoiling is only partially correct, as plant
roots will penetrate through the topsoil into the affected zones, WFC
should commit to additional mitigation if it is found to be necessary
based on the (lack of) success of revegetation efforts. In addition,
it should be made clear that the Division would require such mitigation
even if WFC does not include the commitment in the permit.
3. The narrative on pages 2.04-40(A) and 2.04-42 seem to repeat each
other, therefore, it seems that some rewriting would be in order. In
addition, the narrative states that sample 13 was taken from an
undisturbed area, yet Table 17 lists the sample as waste. This should
be corrected.
In summary, WFC has submitted the new data required by the stipulation.
However, the topsoiling plan is somewhat lacking with respect to remedial
action for potential problem areas. In addition, there are some minor
organizational problems with the permit in this section. In the interests of
expediting the process, I suggest that we approve the TR, either with a
stipulation or with a firm statement that WFC will be responsible for remedial
action should problems related to poor soil quality arise. WFC should be
informed of the problem in (1) above, and the corrections required in (3).
Response to these items would not be a condition of approval, but would be
encouraged, and if necessary pursued at permit renewal.
sak
8392E
423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203-2273 Tel. [phone]