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2010-07-23_REVISION - C1981008
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2010-07-23_REVISION - C1981008
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Last modified
8/24/2016 4:16:46 PM
Creation date
7/26/2010 9:59:42 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
REVISION
Doc Date
7/23/2010
Doc Name
Adequacy Review No. 4
From
DRMS
To
Western Fuels Colorado
Type & Sequence
PR6
Email Name
DAB
MLT
SB1
Media Type
D
Archive
No
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C-1981-008 <br />PR-06 <br />July 23, 2010 <br />Page 29 of 31 <br />79. Amendments requested by this item were provided in Tables 2.05.4(2)(d)-A and 1B. See <br />comments regarding the tables in various previous adequacy comments in this letter, and also <br />see the Division's recommended table modifications attached to this letter. <br />80A. Resolved. Clarification regarding the sampling plan for Bench 1 surface spoil was provided in <br />the amended application. <br />80B. This item requested details for a more closely spaced 2nd phase grid (remedial sampling). See <br />requests in 78D and 78E, above, regarding further clarification needed for Subsection 5.0 and <br />Subsection 15.0 narrative. Item 80B also specifically requested that the more stringent 2nd <br />phase sampling plan and remediation plan as proposed be applied to Sample Site #32 for <br />conductivity. WFC did not respond to the request regarding Sample Site #32 follow-up <br />sampling and remediation. Please confirm that the requested follow-up sampling and <br />remediation will be performed in the vicinity of Sample Site #32, prior to placement of topsoil. <br />80C. This item requested more details on remedial sampling. See requests in 78D and 78E, above, <br />regarding further clarification needed for amended Subsection 5.0 and Subsection 15.0 <br />narrative. <br />80D. This item requested confirmation that burial or backfilling associated with remediation of poor <br />quality soil or spoil would be conducted so as to restore surface topography consistent with <br />postmine management. Such confirmation was provided in amended Section 15.0 for topsoil <br />remediation;, but not in Section 5.0 for spoil remediation. Please provide the same commitment <br />in Section 5..0 as was provided in Section 15.0. Also, we note a couple editorial errors in <br />amended Section 15.0. First, there is an incomplete sentence fragment at the end of the first <br />paragraph following mitigation plan Item #4 ("WFC will maintain"). Second, the commitment <br />to ensure that remedial backfilling/burial maintains appropriate surface topography in the final <br />paragraph of the subsection is stated twice. Please correct these editorial errors. <br />81.-83. Resolved. <br />84. As requested, WFC updated the spoil spring section of the PHC to include a worst case discharge <br />calculation and a more realistic calculation based on current knowledge of the number of acres of <br />irrigated land that will be constructed in reclamation of the New Horizon #2 Mine. WFC also <br />clarified the text description of the expected point of discharge for the New Horizon #2 Mine area <br />spoil spring and added this to Map 2.04.7-1-A. These updates to the text and map are acceptable. <br />However, WFC didn't fully respond to our question regarding the "abandoned" springs associated <br />with New Horizon Mine #1 that are shown on Map 2.04.7-1-A (SS#1 and 2 and SS#3). These <br />springs were renamed on Map 2.04.7-1-A with the latest response, but further clarification is <br />needed with regard to the text description of the New Horizon Mine #1 spoil springs on page <br />2.05.6(3)-38. Spoil Spring #1 is described as follows: "The sample point Spoil Spring 1 <br />represents the spoil water discharge from the New Horizon #1 Mine and has been monitored <br />since 1987.'"' Although the map indicates that it is an abandoned sample site; the text indicates <br />that it is still monitored. From the description of Spoil Spring #1 it is also unclear if the spring is <br />still discharging. There is no discussion of Spoil Springs #2 and #3. Please describe in text all <br />existing spoil springs at the New Horizon Mine #1 include a discussion of whether or not they are
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