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Marcia Talvitie <br />December 23, 2010 <br />Page 3 <br />11. Like Table 2.04.6 -2, the data presentation in Table 2.04.63 is not adequately described. <br />It is unclear if these values are averaged and from what depth or composite interval they <br />were derived. Please clarify this in text and in footnotes to Table 2.04.6 -3. <br />12. Based on our preliminary adequacy review of the application., The Division has <br />determined that WFC has not provided adequate data to determine overburden suitability <br />for plant growth or to identify horizons in the overburden and interburden stratum that <br />may contain potential acid - forming, toxic - forming, or alkalinity- producing materials for <br />the following reasons: 1) WFC noted in the application that there were errors made in the <br />laboratory methodology used to determine "water soluble concentrations" for major and <br />trace elements and "total elemental concentrations" were analyzed instead. The criteria <br />used to establish overburden suitability is based on "water soluble" elemental <br />concentration. 2) There were problems noted with grain size analysis from samples <br />collected during the 2008 drilling program for baseline data collection and the data is of <br />little value as indicated by WFC. 3) Specific analyses required by Rule <br />2.04.6(2)(b)(i)(E), and the Division's "Guidelines for the Collection of Baseline Water <br />Quality and Overburden Geochemistry Data" were not provided with regard to sulfur <br />analysis, and 4) The Division has preliminarily identified inconsistencies in the sampling <br />procedure and the reporting of composite samples and depth intervals for overburden. <br />WFC has presented a special handling procedure for the overburden and interburden as <br />described in Section 2.04.6 of the application. The Division believes that additional data <br />are necessary to determine the appropriateness and adequacy of the proposed handling <br />procedures. The Division has considered various options including requiring additional <br />drilling and overburden sampling and analysis prior to mine plan approval, implementing <br />an overburden sampling program at the initial box cut and during the mining operation, <br />and/or requiring sampling of the overburden to determine suitability prior to topsoil <br />replacement. The Division would like to meet with representatives of WFC to discuss <br />these options. We believe that a meeting would be beneficial to clarify and discuss our <br />questions regarding the adequacy of the overburden physical and chemical property data <br />presented in the application. <br />Let me know if you have questions or require additional information. <br />C: Sandy Brown <br />