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Mr. Dan Matbew.r Division ofMinerals and Geology Page 2 Alto, no sampler wen taken from thegraded highwall dope north of the Channel005-E 1, though it appearr that at leant one and possibly 4 sample locations would have fallen within thin area, bared on a 500 footgrid Finally, then an no sampler from the older reclaimed areas afshe upper `B"Pit and along the ridgekise, between `B"Pit Sample #S, and `~" Pit Sample #35. a) Please explain the reason for the apparent gaps m the samplinggrid m these locations. Ir may be that the olderrec/amation where there are apparentgaps were sampled previously. If so, please provide reference to the report orreports that include the sampling docrunentatlon. Response: Please refer to the 1998 and 1999 Annual Redamadon Reports fox data on these graded azeas. b) Please explain the reason that aU required spoil sampling and evaluation was not completed prior to topsoilirtg, in compliance with approved pernrit. Response: The sampling completed and the success of tevegetation indicates no significant problems exist. If any azea was missed it was due to weather, lake of manpower, or assumptions of competenry, in other words we missed it. The good news is the extensive and comprehensive exam completed by the Division has ensured our future compliance and attention to this important phase. SCC employs the mitigation technique to ameliorate excessive clay content by intensive deep ripping and hummock construction on slopes steeper than 35%, which results in mixing when all spoils aze regraded. c) The Overburden Spoil Aerults section of the Soils Aepart Attachment mater that all regraded spoil samp/es....have suitable quality with na unsuitable parameterr': Thin appears to be the cane for chemical parameters. However, Table 6-3 (Spoil Suitabikty Criteria) ident~er spoil with a clay textural ckus~cation and a SO% orgreater clay fraction ar "Unsuitable Except with Amelioration': Within the original permit area boundary, 8 of the 40 samples men or exceeded the clay unsuitability leve% Six of there sampler wen in the North Mine Black (#34 thmuBh #38, and #40). Four of there (#35 through #38 an clustered in a line along the south highwall slope, in the OOS Gukh watershed #34 and #40 are in the 005E-1 waterrhe~ to the south of the permanent riprapped channel The remaining hvo unsuitable samples (#>9 and #2>) an located in the `~4 "pit reclamation, along the upper segment ofthe 006 Gukb permanent channel, upstream of the of the new Stack Pared T-5. All of these onto sampled in 2004 within the original permit boundary wen topsoiled and reeled between 1999 and 2004. Tab 22 contains an `Tnsuitable Spai! Mitigation Plan'; on pager 4 and 5. Pan 1 of the plan specifier that the area around the suspect hole will be sampled an a closer spacing interval io define ibe lateral extent and variability of the unsuitable material Par? 2 stater that unsuitable clay strata will be ameliorated by intensive deep ripping or chirelin8. i} Please explain why the report narrative states that "all regraded spoil samples...have suitable quality with no tmsuitable parameters'; and amend the narrative as appropriate. Response: Jim Nyenhuis, certified soil sdendst, conducted the evaluation of these samples and felt that the material was suitable. ii) Please address whether and to what extent "intensive deep ripping or chiseling" or othex aspects of the unsuitable spoil mitigation plan speciSed in the permit was implemented within any of the three areas where sampling indicated the presence ofexcessive clay content. Ilthe mitigation plan was not fully implemented, please explain why.