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New Horizon Mine TR-57 <br />2°d Adequacy Review <br />21-Oct-2008 <br />Page 13 of 15 <br />2.05.4(2)(d)-1 "Walsh Report on Subsoil Suitability February 2008 (Revised July <br />2008)", on page (d)-1-4 of the Attachment. Subsoil sample locations are depicted <br />on Figure 1 of the Attachment; March 5, 2008 sample results based on 1:1 <br />extract and June 25, 2008 re-sample results based on saturated paste extract for <br />8 of the original sample locations are reported in Table 2 of the Attachment. <br />June 2008 re-sample results show that two of the 8 subsoil locations exceeded the <br />4.0 mmho standard of Table 2.05.4(2)(d)-1; one by a slight margin (Sample # 21, <br />4.34), and one by a wider margin (Sample #32, 7.33). <br />On amended narrative page 2.05.4(2)(d)-32, the operator indicates that <br />"...Bench 1 subsoil was primarily suitable for all tested criteria. Two samples <br />exceeded the conductivity standard by a small amount." We would agree that <br />the 4.34 mmho value for Sample #21 represents exceedance by a small amount; <br />however the Sample #32 value of 7.33 mmho is of concern; it exceeds the <br />specified standard by a significant margin, and also exceeds the 6.0 mmho value <br />apparently indicated by Dan Dearstyne of NRCS, as potentially being acceptable <br />as an upper limit for prime farmland subsoils (based on reference to discussion <br />with Mr. Dearstyne in amended Attachment 2.05.4(2)(d)-1). <br />Based on the re-sample results, the more intensive sampling program described <br />on amended pages 2.05.4(2)(d)-31 and (d)-32 for prime farmland subsoil is <br />warranted with respect to Sample #32 conductivity. Remedial soil handling in <br />the Sample #32 vicinity may be warranted, depending on the results of the <br />additional intensive sampling (as described in the plan on amended pages <br />2.05.4(2)(d)-31 and (d)-32). <br />Please revise the second paragraph of amended narrative page 2.05.4(2)(d)-32 to <br />more accurately characterize the results of the June 2008 re-sampling for <br />conductivity, and commit to implementation of the remedial sampling/soil <br />handling plan with respect to Sample Site #32, for conductivity. <br />35. Attachments 2.04.9-11 and 2.05.4(2)(d)-1 are largely, but not completely duplicative <br />(there are a couple tables included in one but not the other). There would appear to <br />be no reason for the two separate attachments, and having two attachments that are <br />almost but not exactly the same creates some confusion. Please consolidate the <br />information from the two attachments into a single attachment, and amend the <br />application to contain only the single comprehensive attachment. <br />Item Resolved <br />36. The "Maintenance and Testing Procedure" narrative on page (d)-33 is somewhat <br />outdated, due to the additional parameters (Table 2.04.9-2), more intensive sample <br />grid, and required analysis of individual samples rather than composite samples, <br />associated with the sampling programs described on pages (d)-28 through (d)-30, <br />13