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following commitment is included in Permit Tab 13, page 5, regarding <br />permanent impoundment demonstration of compliance: <br />Permanent impoundments will 6e reevaluated prior to bond release and <br />remedial construction performed to satisfy the appropriate sections of the <br />regulations. Prior to submittal of a bond release request, SCC will <br />submit a complete technical revision demonstrating that each permanent <br />impoundment meets the requirements of 4.05.9(13). <br />D. Acid-forming and Toxic-forming Spoil <br />The applicant has submitted detailed analysis of the geochemical characteristics of <br />the overburden and interburden found in the Seneca II-W Mine permit area. Initial <br />drilling and geochemical sampling was conducted within the baseline study area <br />prior to initiation of operations. Additional drilling and sampling was conducted <br />within the south extension area in 1991. Until approval of PR-3, in 2003, coal <br />extraction was limited to the Wadge seam, and the initial baseline studies were <br />focused on Wadge overburden assessment. Strata from the surface to immediately <br />below the Wadge coal seam were sampled. Core holes were distributed across the <br />Wadge recovery areas in both the original permit area and south extension area <br />(Exhibits 6-6 and 6-6A). <br />PR-3 allowed for surface mining of the Sage Creek and Wolf Creek Seams, as well <br />as the Wadge, within the South Extension area. Characterization and assessment of <br />Sage Creek and Wolf Creek overburden, and Wolf Creek underburden was based <br />on chip samples collected from Monitoring Well WWCU-24, which was drilled <br />into the Wolf Creek underburden near the western boundary of the south extension <br />area in 2001 (Exhibit 7-lA). In addition to the site specific geochemical data from <br />WWCU-24, Sage Creek/Wolf Creek overburden characterization and assessment <br />included consideration of data from the adjacent Yoast Mine permit area, for the <br />same strata. <br />Parameters sampled are listed in the permit application Volume 2, Tab 6. The <br />permit application states that these parameters were used to, "document the <br />physical and chemical properties of the overburden and underburden, to compare <br />these properties to ground water quality, and to determine potential reclamation <br />success." <br />The data obtained from the geochemical analyses were compared to criteria derived <br />from State and Federal agencies (USDA, BLM, Wyoming DEQ, and others). The <br />criteria used for comparison and relative degrees of suitability are listed in Volume <br />2, Tab 6, Table 6-3. Analytical data associated with Wadge overburden and <br />Seneca Q-W Findings Document 29 June 12, 2006 <br />Permit Renewal No. 5 <br />