Laserfiche WebLink
CommenUResponses, TR-62 Page 6 <br />Response: The page from the 2004 Annual Report has been modified to correct the Section <br />8 text discussion. This page is included with this submittal. <br />10. Given the significant reduction proposed with respect to average soil replacement <br />thickness, it would appear to be prudent to re-assess the current regraded overburden <br />pazameter list and suspect levels. Suspect levels for several of the parameters appeaz to <br />be relatively liberal, when compared to typical suspect levels referenced in current <br />literature and guidelines developed by various western state regulatory agencies. For <br />example, Wyoming guidelines list pH values of 5.0 to 5.5, EC levels of 8 to 12, SAR <br />levels of 10 to 12, and selenium levels of 0.3 to 0.8 as marginal, and boron levels in <br />excess of 5.0 ppm as unsuitable. We would suggest that similaz suspect levels would be <br />applicable for Colowyo, unless documentation supporting alternative suspect levels is <br />provided. <br />Please review the current parameter list suspect levels and amend as appropriate. <br />Response: No changes have been made. The list of suitable parameters was recently <br />reviewed and approved under MR-76. With this change, we believe we have adequately <br />addressed both the Wyoming and Colorado suitability levels. <br />11. Colowyo has an ongoing topsoil stripping, replacement and stockpiling operation in <br />advance of the current West Pit and for reclamation of the East Pit. Some of the topsoil <br />is live hauled to regraded spoils but much of the topsoil is stockpiled. Over the summer a <br />large azea was stripped in advance of the West Pit and the topsoil was placed in existing <br />topsoil stockpile 15B. This is similar to what happens every year at the Colowyo Mine. <br />There is no data, however, in the Annual Reclamation Report(s) that details how much <br />topsoil was stripped, where it was stripped, where it was placed (either live-hauled or <br />what stockpile it was placed in) or what areas were exempted from topsoil stripping due <br />to soil conditions (and how these areas relate to the soil mapping units). <br />Please include a description and table of yearly topsoil removal, stockpiling and <br />replacement along with text explaining how Colowyo determines the topsoil volumes <br />removed, stockpiled and replaced as well as information on how Colowyo <br />determines overall topsoil stockpile volumes. Please include this information for <br />each year forward in the Annual Reclamation Report (beginning with the 2005 <br />ARR) including stripping areas, volumes stripped, volumes stockpiled and where <br />they were stockpiled, volumes live handled and areas that have been exempted from <br />topsoil removal. Please include a map of these areas as well. <br />Response: This comment appears to be similar to the issue identified in Comment 4. We <br />concur that this analysis would be helpful. A permit commitment has also been added. <br />