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New Horizon Mine TR-57 <br />2nd Adequacy Review <br />21-Oct-2008 <br />Page 3 of 15 <br />• The methodology associated with the proposed coarse fraction limits in <br />Narrative Table 2.04.9-2 appears to be consistent with the methods used <br />to obtain the values reported in amended Table 2 of amended Attachment <br />2.05.4(2)(d)-1. <br />Item Resolved <br />The suitability level for selenium (2 ppm) appears to be relict from original <br />permitting activities. Current guidelines available from other western states indicate <br />more stringent marginal levels or suspect levels for selenium (e.g. 0.1 ppm suspect <br />level in Montana, 0.4-0.8 marginal levels in Wyoming). Colorado does not have a <br />Soils/Overburden guideline document, but typically we accept suitability levels <br />established based on Wyoming or Montana guidelines, or independent documentation <br />based on relevant current literature. As such, the suitability level for selenium may <br />need to be amended. <br />Conversely, if previous soil sampling and sampling of Bench 1 overburden that could <br />potentially be placed in the root zone has documented the absence of elevated levels <br />of selenium, continued analysis of selenium within replaced topsoil, subsoil, or root <br />zone overburden may not be warranted. Please address this concern, provide <br />appropriate documentation, and amend the table as appropriate. <br />Item Resolved <br />6. The statement in the first paragraph under Prime Farmland Determination - 2008, <br />that there are 107.96 acres of 98E Map Unit in the permit boundary is somewhat <br />misleading. The 107.96 acres would appear to be the entire acreage of the Morgan <br />property in the permit area, southwest of the intersection of BB Road and 2700 Road. <br />This property is dominated by the 98E map unit, and the entire property will be <br />treated as prime farmland. Limited areas of the 98E map unit located to the east of <br />2700 road in the permit area are also depicted on Map 2.04.9-1, but these areas have <br />been previously reclaimed under the permitted assumption that the units were not <br />prime farmland. Please clarify that the 2008 prime farmland determination <br />regarding 98E and 98A map units applies to permitted areas located to the west of <br />2700 Road, and provide a more accurate description of the area encompassed within <br />the referenced 107.96 acres. <br />Item Resolved <br />7. The NRCS letter included in Attachment 2.04.9-10 addresses the Prime Farmland <br />determination for the Barx and Darvey soil series (Map Unit 98E), but the attachment <br />does not include NRCS letter identifying the Begay soil series (Map Unit 98A) as <br />Prime Farmland. Please include the 2008 NRCS letter identifying the Begay soil <br />series as Prime Farmland, in Attachment 2.04.9-10. <br />Item Resolved <br />8. Please provide documentation, including NRCS concurrence, to support the <br />statements in the final paragraph on page 2.04.9-15, that specified small parcels of <br />3