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J ~ <br />Mr. Allen D. Klein -2- ~ November 8, 1982 <br />2. The Division feels that, for the purpose of. evaluating potential <br />impact of overburden chemical properties on revegetation, the sampling <br />plan proposed by Colowyo is acceptable. By intensively sampling <br />overburden above the upper three seams (which will be handled by the <br />truck shovel operation and dumped on top of the dragline spoil), the <br />sampling density will be higher than the commonly recommended 1 bore <br />hole per square mile. The Division takes exception to the implication <br />that baseline information requirements of Rule 2.04.6 have not been <br />met. Rule 2.04.6(1)(b)(ii) requires that bore hole spacing and <br />physical and chemical analyses of core samples be determined in <br />consultation with the Division. In the Division's opinion, the base- <br />line geology and hydrology information supplied by Colowyo was <br />adequate to make the required findings of compliance. <br />3.~ The averaging effect of the composite samples will be minimized by , <br />the fact that separate samples will be collected for the overburden <br />associated with each coal seam. If a significant volume of toxic <br />strata is encountered, the Division feels that its presence would be <br />reflected in the initial analyses. At that point, a specific sampling <br />program designed to further define the characteristics and extent <br />of the toxic strata would be developed and implemented. <br />4. If any potentially toxic spoil is encountered, Colowyo .has committed <br />within the application to complete additional sampling and analysis <br />and to formulate plans for handling the toxic material. <br />The suggestion to sample replaced spoils prior to topsoil redistribution <br />has obvious merit. There is a possibility that isolated bodies of <br />toxic strata would not be detected by the composite analyses. If <br />such material were to be placed on the surface, it could be identified <br />by sampling prior to topsoiling and appropriate mitigative measures <br />could be taken. Colowyo has indicated that they would not be averse <br />to submitting aminor revision request to include sampling of <br />replaced overburden as part of their overburden monitoring plan. <br />I hope the above explanation is sufficient to allay each of the concerns <br />specified in your November 2, 1982 letter. The sampling plan will be <br />modified to include overburden sampling prior to topsoil replacement. <br />If you or members of your staff have further questions regardiny this <br />matter, please contact Brian Munson or me. <br />Sincerely, <br />/~~ n <br />Dan T. Mathews <br />Reclamation Specialist <br />bTM/mmt <br />