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2011-05-05_REVISION - C1981008
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2011-05-05_REVISION - C1981008
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Last modified
8/24/2016 4:33:19 PM
Creation date
5/6/2011 1:49:38 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981008
IBM Index Class Name
REVISION
Doc Date
5/5/2011
Doc Name
Adequacy Review No. 4 Letter
From
DRMS
To
Western Fuels-Colorado
Type & Sequence
SL12
Email Name
MLT
SB1
Media Type
D
Archive
No
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C-1981-008 - SL-12 <br />Adequacy Review No. 4 <br />5 May 2011 <br />Page 9 of 10 <br />probability of 0.2) the conclusion remains the same; reclaimed area mean production is greater than <br />90% of reference area mean production. We were able to intentionally create the parenthesis error and <br />obtained the same erroneous value as the consultant, and this value (3705.3) is also listed on the <br />Attachment 2 spreadsheet. <br />c) The same minor error (use of alpha error probability value of 0.1 for table t-statistic), and the same more <br />serious error (Excel formula error with resultant extremely high value for the calculated t-statistic) were <br />both incorporated into the success demonstrations for the 2008 IP production data, the 2007 Dryland <br />Pasture production data, and the 2008 Dryland Pasture production data. <br />Please re-run the 2-sample reverse null t-tests for 2007 and 2008 IP and DP production success <br />demonstrations using the appropriate .02 alpha error probability for the table t-statistic, and the corrected <br />Excel formula for the calculated t-statistic, and revise Production Text Tables 2, 4, 6, and 8 with the <br />corrected values. If the success results for any particular comparison change or are reversed based on the <br />corrected test results, the corresponding "Comparison to Standard" narrative will need to be revised, along <br />with other narrative sections of the application, as appropriate. <br />With the Aug. 2010 response, the appropriate corrections were made to the Nest formula and the <br />reclamation success statistical analysis was recalculated correctly. The tables were corrected. Item <br />resolved. <br />Soil Loss for Phase H <br />The Division transmitted adequacy comments related to soil loss in a memo (effectively Adequacy Review No. 3) <br />dated March 28, 2011. The comments, numbered as in the original memo, are incorporated below. In WPC's <br />response, received on March 31, 2011, the soil loss comparison was revised. While the calculated sediment loss <br />for the post-mining situation is actually larger than that for the pre-mining condition, the calculated soil loss <br />values are so small that the Division agrees with WPC's argument that there is essentially no sediment loss for <br />both pre-mine and post-mine conditions. <br />Concerning the determination of the soil erodibility factor "K" on page 17, a statement is made that the soil <br />on the reclaimed area is similar to the soil that was salvaged from that area before mining. However, <br />comparison of the soil types listed in Table 1 on page 18 with the baseline soil types shown on soil Map <br />2.04.9-1 appear to show a couple of discrepancies. First, Barx soil and Ustic Torriorthents are listed in Table <br />1 but do not appear in the phase 2 release area shown on Map 2.04.9-1. Second, soil types Bowbac-Bowdish <br />Complex, Haplargids-Endoaquolls Association, Bowdish-Bowbac Complex and Wahweap, map units 98D, <br />98F, 98G and 98H respectively, are shown on Map 2.04.9-1 in the phase 2 release area but do not appear in <br />Table 1. Please explain. <br />In the March 31, 2011 response, WFC revised page 18, and added a note to the bottom of Table I on page <br />19 to explain that NRCS soil survey designations were used for the soil loss comparison for SL-12, whereas <br />the pre-mine baseline soil survey did not. An examination of the applicable soil types shown on the NRCS <br />website verified the SL-12 soil type information. Item resolved. <br />2. For the cover factor "C" determination for the pre-mine condition for irrigated pasture, there appears to be a <br />minor math miscalculation at the top of page 22. The final "C" factor of .0258 was obtained by adding .0008 <br />to .025. It appears, however, that .0008 should be subtracted from .030, resulting in a value of .0292. If you <br />agree, please revise pages 22, 23 and 29 accordingly. If you do not agree, please explain. <br />WFC revised the methodology concerning the alfalfa cover in the March 31, 2011 response. This cover <br />factor calculation is no longer needed. Item resolved. <br />3. For the cover factor "C" determination for the post-mine condition for irrigated pasture, there appears to be a <br />minor math miscalculation in the middle of page 23. The change, however, would not affect the result but it
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