2010-12-23_APPLICATION CORRESPONDENCE - C2010089

Home Browse Search

C- 2010 -089 PAR Part 1 23- Dec -2010 New Horizon North Mine Page 10 of 21 4. The footnote to Appendix Table 2.06.6 -2 also has an incorrect reference to the EPA Method. Please make the appropriate corrections. 5. For the trace elements in Table 2.04.6 -2, the listings under Parameters/Units are confusing. Take Boron for example, it is shown as Tot. B, (Sol. B.), mg /kg. Please footnote and clarify what is meant by (Sol.) and provide the proper units for these analyses. 6. It is not clearly explained how the overburden analytical data are presented when comparing Table 2.0.4.6 -2 and Appendix Table 2.04.6 -2 with the laboratory analytical reports contained in Appendix 2.04.6 -3. There are numerous samples listed on the laboratory reports for East Nest, Northwest Nest, and Southwest Nest which presumably correlate to NA08 -E, NA08 -NW, NA -08 SW, respectively. There is no depth correlation to the data in either Table 2.04.6 -2 or Appendix 2.04.6 -3 and it is unclear how these correlate to the data provided in Appendix Table 2.04.6 -2. It appears that the data presented in Table 2.04.6 -2 are average values calculated from composite samples but this is not described or footnoted. Our "Guidelines for the Collection of Baseline Water Quality and Overburden Geochemistry Data" has specific recommendations for sampling each individual stratum and recommended thickness intervals for composite samples. 7. The presentation of the analytical data for the overburden needs to be further clarified. Please ensure that all data presented in Table 2.04.6 -2 and Appendix Table 2.04.6 -2 is easily correlated with the laboratory analytical data presented in Appendix 2.04.6 -3. 8. Please provide the analytical laboratory reports for the data presented in Table 2.04.6 -2 for the five (5) overburden sample holes (1C, 3C, 695E, 697E and 775E) for which data are provided from New Horizon 1 Mine Area. This information should be provided in an Appendix to this permit application. 9. Like Table 2.04.6 -2, the data presentation in Table 2.04.6 -3 is not adequately described. It is unclear if these values are averaged and from what depth or composite interval they were derived. Please clarify this in text and in footnotes to Table 2.04.6 -3. 10. Based on our preliminary adequacy review of the application, the Division has determined that WFC has not provided adequate data to determine overburden suitability for plant growth or to identify horizons in the overburden and interburden stratum that may contain potential acid - forming, toxic - forming, or alkalinity - producing materials for the following reasons: 1) WFC noted in the application that there were errors made in the laboratory methodology used to determine "water soluble concentrations" for major and trace elements, and "total elemental concentrations" were analyzed instead. The criteria used to establish overburden suitability is based on "water soluble" elemental concentration. 2) There were problems noted with grain size analysis from samples collected during the 2008 drilling program for baseline data collection and the data is of little value as indicated by WFC. 3) Specific analyses required by Rule 2.04.6(2)(b)(i)(E), and the Division's "Guidelines for the Collection of Baseline Water Quality and Overburden Geochemistry Data" were not provided with regard to sulfur analysis, and 4) The Division has preliminarily identified inconsistencies in the sampling procedure and the reporting of composite samples and depth intervals for overburden. WFC has presented a special handling procedure for the overburden and interburden as described in Section 2.04.6 of the application. The Division believes that additional data are necessary to determine the appropriateness and adequacy of the proposed handling procedures. The Division has considered various options including requiring additional