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growth or to identify horizons in the overburden and interburden stratum that may contain <br />potential acid-forming, toxic-forming, or alkalinity-producing materials for the following <br />reasons: 1) WFC noted in the application that there were errors made in the laboratory <br />methodology used to determine "water soluble concentrations" for major and trace elements, <br />and "total elemental concentrations" were analyzed instead. The criteria used to establish <br />overburden suitability is based on "water soluble" elemental concentration. 2) There were <br />problems noted with grain size analysis from samples collected during the 2008 drilling <br />program for baseline data collection and the data is of little value as indicated by WFC. 3) <br />Specific analyses required by Rule 2.04.6(2)(b)(i)(E), and the Division's "Guidelines for the <br />Collection of Baseline Water Quality and Overburden Geochemistry Data" were not <br />provided with regard to sulfur analysis, and 4) The Division has preliminarily identified <br />inconsistencies in the sampling procedure and the reporting of composite samples and depth <br />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 are <br />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 an <br />overburden sampling program at the initial box cut and during the mining operation, and/or <br />requiring sampling of the overburden to determine suitability prior to topsoil replacement. <br />The Division would like to meet with representatives of WFC to discuss these options. We <br />believe that a meeting would be beneficial to clarify and discuss our questions regarding the <br />adequacy of the overburden physical and chemical property data presented in the <br />application. <br />Response -A meeting with DRMS personnel was held on February 1, 2011 in Grand <br />Junction to discuss this issue. Western Fuels has collected additional overburden samples <br />in three locations to replace the previous sampling results. These samples have been <br />analyzed in accordance with the "Guidelines for the Collection of Baseline Water Quality <br />and Overburden Geochemistry Data". These results are included in Appendix 2.04.6-3. <br />2.04.7 - Hydrology Description <br />2.047(1) - Ground Water Information <br />1. In the second paragraph on page 2 of Section 2.04.7, WFC states that completion diagrams <br />for nine new monitoring wells are contained in Appendix 2.04.7-1. Actually only "typical" <br />completion diagrams were provided, one for each of three monitoring zones. Please correct the <br />statement on page 2 as follows: "Typical completion diagrams one each for the overburden, <br />coal zone, and underburden well completion monitoring zones are provided in Figure 1 of <br />Appendix 2.04.7-1." <br />Response - Corrected <br />Response to First Adequacy Review Page 1S