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iii-iiiiiii--iiiii <br />January 26, 1992 <br />TO: Harry Ranney <br />FROM: Tony Waldron <br />RE: New Horizon Mine C-81-008, Revision Review <br />As requested, I have completed my preliminary review of the new <br />horizon mine revision. There are several areas where I would like <br />to conduct a more through investigation before drawing any <br />conclusions. In addition there are several areas where a face to <br />face meeting would probably provide a better format to work out <br />some of the details than reams of correspondence. Initially, I have <br />the following comments. <br />Sampling Methodology <br />This section is laid out in an organized manner and provides lots <br />of background information for why certain tests are conducted. The <br />one concern I have about this section is under the heading <br />"Mitigative Measures For Marginally Unsuitable Material". This <br />section is actually discussed in more detail under section <br />2.05.4(2)d (topsoil redistribution). The concern is with <br />potentially acid forming materials and how they will be handled to <br />mitigate potential acidic overburden. The operator indicates that <br />by mixing with a buffering spoil that any problems will be avoided. <br />This may be true but I would like to see the data on the acid base <br />potential if one was run showing that any acid material would be <br />neutralized by an appropriate amount of basic material. <br />Soils Resource Information <br />Previously under this section( When Peabody owned the mine) Prime <br />Farmland had been identified in the area. The currant operator now <br />claims that no prime farmland exist in the area to be mined. This <br />is supported by the local SCS in a letter to Andy Boudreau dated <br />October 14, 1992. The letter states that only one soil has the <br />potential to be prime and only if irrigated with a dependable <br />supply of water. The letter then states that there is not a <br />dependable supply of water and therefore the unit is not prime. <br />However, throughout the various soil and vegetation sections <br />numerous references are made to the wet soils and irrigated crops <br />in the area and even to the fact that some soils may not be able to <br />be salvaged due to their wetness etc., etc. Based on this <br />conflicting information this area (prime farmlands) will need to be <br />addressed and the whole issue clarified before approval. <br />