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New Horizon Mine TR-57 <br />2nd Adequacy Review <br />21-Oct-2008 <br />Page 2 of 15 <br />3. Soil analytical data from the 1998 study is included in Appendix 2.04.9-7, referenced <br />in narrative page 2.04.9-12. Op Attachment page 2.04.9-7-11 the columns are shifted <br />or misaligned, such that some of the parameter listings do not fall under the <br />appropriate column heading, making the data on that page difficult to interpret. <br />Please provide a revised Attachment page 2.04.9-7-11, with columns correctly <br />aligned beneath appropriate headings. <br />Item Resolved <br />4. The suitability levels for coarse fragment content for Prime Farmland Lift B and <br />Single-Lift Soils in Table 2.04.9-2 will need to be further explained and documented. <br />Typical upper limit recommendations for root zone coarse fragment content are in the <br />range of 30% to 35% by volume. The proposed standard would allow for coarse <br />fragment content of up to 50% in individual locations, with an over-all average coarse <br />fragment content of 25%. Notation 5 to the table indicates that, for prime farmland <br />Lift A at least, the suitability levels for total coarse fragments and fragments greater <br />than 3" diameter, would be based on weight. Coarse fragment suitability limits are <br />typically presented as percent by volume (initial calculation may be by weight, and <br />then converted to volume). Email correspondence from David Dearstyne of NRCS to <br />Edward Baltzer of Walsh Environmental, included in Attachment 2.04.9-11, <br />recommends sampling of percent rock fragment sizes and amount by volume. In a <br />letter of March 20, 2008 to Ross Gubka, Mr. Baltzer states that percent coarse <br />fraction and other information was recorded into a field notebook and transferred to <br />Table 2 of Attachment 2.04.9-11. Presumably, the coarse fraction estimates included <br />in Table 2 of the attachment, for the replaced Bench 1 subsoil substitute material, are <br />percent by volume, but this is not specified. <br />Please revise Table 2.04.9-2 to specify that proposed coarse fraction limits are based <br />on % by volume, or, if applicable, provide documentation to support use of limits <br />based on % by weight. Also, please specify in footnote to Table 2 of Appendix 2.04.9- <br />11, whether reported coarse fragment % values are based on weight or volume, and <br />provide detail regarding the procedure used. Finally, please specify a Lift B upper <br />limit of 35% by volume for individual sample locations, or provide <br />rationale/documentation to support the 50% individual / 25% average limits <br />proposed. The methodology associated with the proposed limits should be consistent <br />with that used to obtain the values reported in Table 2 of Attachment 2.04.9-11. <br />In the 7/31/08 amendment package, we note the following: <br />• Narrative Table 2.04.9-2, Footnote 5, was amended to specify that coarse <br />fraction limits are based on percent by volume. <br />• Lift B upper limit of 35% by volume for individual sample locations was <br />specified in Narrative Table 2.04.9-2, Footnote 5. <br />• The requested clarification of Table 2 of Attachment 2.04.9-11 was <br />provided in amended Table 2 of amended Attachment 2.05.4(2)(d)-1. <br />Attachment 2.04.9-11 appears to have been duplicative, and was properly <br />deleted. <br />2