2010-05-07_PERMIT FILE - C2009087 (14)

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• have a detailed guideline with specifications for conducting a baseline soil resource assessment, reference is also made to the current Wyoming Department of Environmental Quality (WDEQ) Guideline No.1 "Topsoil and Overburden" (WDEQ, 1996). The soils scope -of -work was discussed with CDRMS personnel at a meeting in June 2008 that was attended by Mr. Vern Pfannenstiel (Manager, Environmental Services /Reclamation — West, Peabody Investment Corporation). Subsequent discussion also occurred between Jim Nyenhuis and Mr. Dan Hernandez ( CDRMS) in September 2008 prior to the start of soils field work. The main soils requirement is that a detailed Order 1 or 2 intensity soil survey be completed on all potentially disturbed surface areas projected for the Sage Creek Mine. This requirement is consistent with specifications of WDEQ Guideline No.1, as described on pages 2 and 3 of that guideline, which further states that non - affected areas need only be mapped less intensively to the Order 3 level or better (WDEQ, 1996). Soils mapping of the probable non - affected portion of the Soils Study Area, approximately 11,114 acres in size, was recently completed to the detailed Order 2 level (NRCS, 2007; Peacock, 2009) by the USDA Natural Resources Conservation Service (NRCS) as part of their Routt County Area Soil Survey (NRCS, 2008). In addition, a portion of the non - affected area is also within the current Seneca II Mine permit area and as such was mapped to the Order 1 -2 level as part of the Seneca II Mine baseline soil survey. • Portions of the Sage Creek Mine potential surface - affected areas are within currently permitted areas of the Seneca II Mine and Twentymile Coal's Foidel Creek Mine. The primary mine -portal area, several additional portal /pothole excavation areas, and a small portion of the waste rock storage area are entirely within the current Seneca II Mine permit area. In addition, a large portion of the potential transportation corridor overlaps the Foidel Creek Mine permit area. Based on discussion with CDRMS (Hernandez, 2008), these areas would not need to be remapped and sampled because they have already been mapped in detail to either the Order 1 or 2 level of intensity and characterized as part of the previously completed Foidel Creek Mine soils baseline studies ( Twentymile Coal Company, 1999). However, the previous Seneca II Mine soils mapping of these areas was field- checked and refined when it was delineated onto the new Sage Creek Mine project base map which is a recent (September 2008) air -photo map. The mapping refinement also adopted the current extent of Seneca II Mine reclaimed land as delineated on their "Phase III Bond Release" map (Seneca Coal Company, 2008). The previous Foidel Creek Mine soils mapping was also field- checked and transferred to the new project base map. The remaining areas of potential surface disturbance that need additional soils mapping and sampling to the Order 1 -2 level of intensity include: (1) most of the potential waste rock storage area, located immediately adjacent to the northwest side of the Seneca II Mine permit area, and (2) a portion of the potential transportation corridor that lies in hilly terrain • 2