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b) Please explain the reason that all required regraded spoil sampling and evaluation was not completed prior to topsoiling, in compliance with the approved permit. c) The Overburden Spoil Results section of the Soils Report Attachment states that "all regraded spoil samples...have suitable quality with no unsuitable parameters". This appears to be the case for the chemical parameters. However, Table 63 (Spoil Suitability Criteria) identifies spoil with a clay textural classification and a 50% or greater clay fraction as "Unsuitable Except with Amelioration". Within the original permit area boundary, 8 of the 40 samples met or exceeded the clay unsuitability level. Six of these samples were in the North Mine Block 1#34 through #38, and #40). Four of these (#35 through #38 are clustered in a line along the south highwall slope, in the upper 005 Gulch watershed. #34 and #40 are in the 005E-1 watershed, to the south of the permanent riprapped channel. The remaining two unsuitable samples (#19 and #21) are located in the "A" pit reclamation, along the upper segment of the 006 Gulch permanent channel, upstream of the new Stock Pond T-5. All of the areas sampled in 2004 within the original permit boundary were topsoiled and seeded between 1999 and 2004. Tab 22 contains an "Unsuitable Spoil Mitigation Plan", on pages 4 and 5. Part 1 of the plan specifies that the area around a suspect hole will be sampled on a closer spacing interval to define the lateral extent and variability of the unsuitable material. Part 2 states that unsuitable clay strata will be ameliorated by intensive deep ripping or chiseling. i) Please explain why the report narrative states that "all regraded spoil samples...have suitable quality with no unsuitable parameters", and amend the narrative as appropriate. ii) Please address whether and to what extent "intensive deep ripping or chiseling", or other aspects of the unsuitable spoil mitigation plan specified in the permit was implemented within any of the three areas where sampling indicated the presence of excessive clay content. If the mitigation plan was not fully implemented, please explain why. iii) If remedial measures have not been implemented, please address measures that will be taken during the current field season. For areas that were seeded several years previously, the logical initial step would entail an assessment of apparent revegetation success in the subject areas, supplemented by test pits to evaluate rooting characteristics, and to further delineate the areas with excess clay content. 10. The approved permit also describes postmine spoil/highwall sampling and mitigation to be applied within the reclaimed Wedge and Wolf Creek mining blocks of the South Extension Area. Page 9 of Tab 6 describes potential concerns with acid forming potential associated with Wolf Creek overburden, based on overburden analyses from the Yoast Mine, and states that a spoil sampling program will be conducted in the Wolf Creek mining block as described in Tab 21. On page 40 of Tab 6, there is discussion of concern regarding excessive clay levels in shale strata overlying the Lennox seam, and concern with potential acidity associated with the Lennox seam and encapsulating strata. A sampling plan will be used near the Lennox coal outcrop as shown on Exhibit 6-6 and throughout the southern mine b/ock to identify final graded areas having an unsuitable c/ay, pH, end/or acid base potential /eve% The unsuitable shale and clay strata encountered in the reduced