2012-01-13_APPLICATION CORRESPONDENCE - C2010089 (2)

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C -2010 -089 New Horizon North Mine PARNos. 1- 1A -1B, 2- 2A -2B, 3 Page 14 of 60 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. Rein resolved in M07- :2011 r es]7onse. 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 drilling and overburden sampling and analysis prior to mine plan approval, implementing an overburden sampling program at the initial box cut and during the mining operation, and/or requiring sampling of the overburden to determine suitability prior to topsoil replacement. The Division would like to meet with representatives of WFC to discuss these options. We believe that a meeting would be beneficial to clarify and discuss our questions regarding the adequacy of the overburden physical and chemical property data presented in the application. A meeting was held between DRMS and WFC on l -Feb- 2011. WFC collected additional overburden samples in three locations to replace the previous sampling results. The new results are included in Appendix 2.04.6 -3. ,Item resolved in ay -2011 re sp nse. 2.04.7 Hydrology Description 2.0-1.7 I Ground Water Aijbrivation In the second paragraph on page 2 of Section 2.04.7, WFC states that completion diagrams for nine new monitoring wells are contained in Appendix 2.04.7 -1. Actually only "typical" completion diagrams were provided, one for each of three monitoring zones. Please correct the statement on page 2 as follows; "Typical completion diagrams one each for the overburden, coal zone, and underburden well completion monitoring zones are provided in Figure I of Appendix 2.04.7 -1.