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Greg Lewicki And Associates <br />11541 Warrington Court Phone (303) 346-5196 Fax: (303)-346-6934 <br />Parker, CO USA 80138 E-Mail:info@lewicki.biz <br />July 6, 2010 <br />Lance Wade <br />Western Fuels Colorado <br />PO BOX 628 <br />Nucla, CO 81424 <br />Dear Lance: <br />I have reviewed the approved Section 2.05.4(2)(d) Topsoil Redistribution for the New <br />Horizon Mine with regard to soil suitability testing, and with regard to the recent <br />violation that was issued for this testing. This Section was resubmitted in March of <br />2008, once the prime farmland soils were determined by the NRCS and we had <br />numerous meetings and phone calls with the Division and NRCS about how to <br />immediately address the soil handling procedures at the mine. After very significant <br />review, the Technical Revision was approved in early 2009. <br />I have the following comments regarding the approved Section and the recent violation. <br />1) As seen on the following page from the approved Section 2.05.4(2)(d) from TR 57, <br />there is a specific plan where the sampling of bench 1 material is addressed as spoil. <br />2) Table 2.05.4(2)(d)-1 is the Table to determine all topsoil sampling at the mine after <br />the TR-57 approval. Much time was spent in developing this table with input from the <br />Division, NRCS and WFC. I, Greg Lewicki, P.E., wrote this section and it was always <br />my understanding that this table was the specific guideline for all sampling of the <br />replaced topsoil at the mine. The table shows in the far right column that Prime <br />Farmland Lift B and Single Lift Soils must be tested for the parameters listed below it. <br />There is nothing saying that the subsoil in Single Lift Soils areas was to be tested. It <br />was never our understanding that this was the case. <br />3) The last page included (page 33) shows (highlighted in yellow) that 30" of Bench 1