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2011-06-02_APPLICATION CORRESPONDENCE - C2010089 (10)
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2011-06-02_APPLICATION CORRESPONDENCE - C2010089 (10)
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Last modified
8/24/2016 4:34:06 PM
Creation date
6/3/2011 8:50:28 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C2010089
IBM Index Class Name
APPLICATION CORRESPONDENCE
Doc Date
6/2/2011
Doc Name
Response to Preliminary Adequacy Review
From
Western Fuels Association
To
DRMS
Email Name
MLT
SB1
Media Type
D
Archive
No
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Response - Table 2.04.6-2 has been replaced. <br />4. The footnote to Appendix Table 2.06.6-2 also has an incorrect reference to the EPA Method. <br />Please make the appropriate corrections. <br />Response - Table 2.04.6-2 has been replaced. <br />5. For the trace elements in Table 2.04.6-2, the listings under Parameters/Units are confusing. <br />Take Boron for example, it is shown as Tot. B, (Sol. B.), mg/kg. Please footnote and clarify <br />what is meant by (Sol.) and provide the proper units for these analyses. <br />Response - The table has been revised to include the replacement drill holes (NHNI1-1, <br />NHN11-2 and NHNII-3). The footnote referring to Tot (SoL) has been remove. Only Sol. <br />(soluble) parameters are now shown. <br />6. It is not clearly explained how the overburden analytical data are presented when comparing <br />Table 2.0.4.6-2 and Appendix Table 2.04.6-2 with the laboratory analytical reports <br />contained in Appendix 2.04.6-3. There are numerous samples listed on the laboratory <br />reports for East Nest, Northwest Nest, and Southwest Nest which presumably correlate to <br />NA08-E, NA08-NW, NA-08 SW, respectively. There is no depth correlation to the data in <br />either Table 2.04.6-2 or Appendix 2.04.6-3 and it is unclear how these correlate to the data <br />provided in Appendix Table 2.04.6-2. It appears that the data presented in Table 2.04.6-2 <br />are average values calculated from composite samples but this is not described or footnoted. <br />Our "Guidelines for the Collection of Baseline Water Quality and Overburden Geochemistry <br />Data" has specific recommendations for sampling each individual stratum and <br />recommended thickness intervals for composite samples. <br />Response -A revised Appendix Table 2.04.6-2 is included. It was created with the new <br />overburden sample data. <br />7. The presentation of the analytical data for the overburden needs to be further clarified. <br />Please ensure that all data presented in Table 2.04.6-2 and Appendix Table 2.04.6-2 is easily <br />correlated with the laboratory analytical data presented in Appendix 2.04.6-3. <br />Response -A revised Appendix Table 2.04.6-3 is included. It was created with the new <br />overburden sample data. <br />8. Please provide the analytical laboratory reports for the data presented in Table 2.04.6-2 for <br />the five (5) overburden sample holes (1C, 3C, 695E, 697E and 775E) for which data are <br />provided from New Horizon 1 Mine Area. This information should be provided in an <br />Appendix to this permit application. <br />Response - Included in Appendix 2.04.6-4 Peabody Coal Analysis. <br />9. Like Table 2.04.6-2, the data presentation in Table 2.04.6-3 is not adequately described. It <br />is unclear if these values are averaged and from what depth or composite interval they were <br />derived. Please clarify this in text and in footnotes to Table 2.04.6-3. <br />Response -A new Table 2.04.6-3 has been created based on the new overburden data. <br />10. Based on our preliminary adequacy review of the application, the Division has determined <br />that WFC has not provided adequate data to determine overburden suitability for plant <br />Response to First Adequacy Review Page 14
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