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values are identified by the regraded spoil quality control program. Reclamation practices will <br />include selectively handling of suitable spoil topdressing. <br />4.0 Regraded Spoil Monitoring Program <br />In order to provide a feedback system to check the reliability of the overburden sampling and <br />analysis program, a regraded spoil sampling program will be initiated. The upper four feet of <br />regraded spoil will be sampled prior to topsoil replacement with a hydraulic soil sampler, a <br />bucket auger, or other suitable equipment to ensure that a suitable root growth medium was <br />provided. Two representative samples, each representing a two -foot depth increment, will be <br />collected on a 600ft x 600ft grid. The vertical sampling increments were 0.0 to 2.0 feet and 2.0 <br />to 4.0 feet. Personnel will inspect the surface spoil between grid points. If a significant change <br />in spoil characteristics is observed between grid points, additional sample sites would be <br />located. Regraded spoil will also be visually inspected for compaction, possible root growth <br />problems, and the potential for slippage at the topsoil /spoil interface. The lateral and vertical <br />sampling intensities will be closely evaluated once sufficient samples is collected to determine <br />the degree of sample variability. This sampling program will ensure that the top four feet of <br />regarded spoil is non -toxic and chemically /physically suitable to enhance plant growth. <br />Originally, the regraded spoil samples will be analyzed for the following parameters to <br />determine spoil suitability: PH, acid base potential, boron particle size (texture), saturation <br />percent, EC, and SAR. The parameter list is based upon the baseline information acquired <br />during the pre -mine overburden sampling program (Section 2.04.6). As part of the spoil <br />monitoring program, regraded spoil is analyzed for a list of parameters for suitability. One item <br />in this list is boron. It is believed that Peabody included this parameter in the test list for spoil as <br />a precautionary item since they used a dragline to move overburden at that time and they had <br />no ability to segregate the Bench 1 material and place it below the topsoil zones. A study of all <br />the past years analyses has shown that the Bench 1 material has always tested below 5 ppm, <br />which is the normal threshold limit for boron in the subsoil. Nevertheless, it will continue to be <br />studied in the spoil testing program but will not be part of the Lift B testing described in Table <br />2.05;.4(2)(d) -1. <br />(Reviwd Odober 2009) 2.05.4(2)(d) -g <br />