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U <br />Mr. Brock Bowles <br />November 12, 2015 <br />Page 2 <br />2.05.3(3) — Mine Facilities <br />1. Response: Item Resolved. <br />2. Response: Item Resolved. <br />3. Response: Item Resolved. <br />2.05.4(2)(b) — Reclamation Cost Estimate <br />1. Response: Item Resolved. <br />2.05.4(2)(d) — Topsoil Redistribution <br />1. Response: Item Resolved. <br />2. Response: Item Resolved. <br />3. Response: Item Resolved. <br />4. Response: Item Resolved. <br />5. The Bench 1 parameters and suitability in proposed Table 2.05.4(2)(d)-1 are different than those <br />currently listed in the approved permit. Please explain and clam why the parameters and <br />suitability standards have changed. <br />Response: The values in Table 2.05.4(2)(d)-1 Criteria for Evaluating Bench I Suitability were <br />necessarily adjusted because many of the values listed in the tables either conflicted, were <br />significantly different than what is generally considered scientifically sound threshold values, or <br />have an unknown formulation. The Bench 1 Material is intended to be used as a subsoil rooting <br />media. Some values in the original table were too stringent even for topsoil, while others would <br />allow for unsuitable subsoil rooting media. <br />For example, SAR (sodium adsorption ratio) and ESP (exchangeable sodium percentage) are <br />essentially the same value, and are very similar methods for investigating the same soil property <br />(sodicity). Yet, in the original table, both tests were required, and had significantly different <br />threshold criteria (SAR=6 and ESP=15). It is commonly accepted that the sodic soil threshold is <br />a value of 13-15 for SAR depending on the source, and 15 for ESP. Since Bench 1 material is <br />being used as subsoil, a traditional value of 15, and only testing for one of these parameters is <br />more appropriate than redundant testing, and a conflicting definition of success. <br />Another example is evident with the "Acid Base Potential" parameter. The suitability threshold <br />for this value was 6, yet it is unclear whether this 6 translates as Acid:Base or Base:Acid. It <br />seems that the author intended this to be Base:Acid, yet a value of 6 states than there would need <br />to be 6x the neutralization potential than acid formation potential, which is significantly higher <br />than is required to negate acid production. A value of 2 is more realistic yet still conservative, as <br />having double the neutralization potential than acid potential leaves significant room for success, <br />despite the inherent error involved in these tests. The name of this analysis was changed from <br />AN EQUAL OPPORTUNITY/ AFFIRMATIVE ACTION EMPLOYER <br />A Touchstone Energy Cooperative <br />