2010-12-23_APPLICATION CORRESPONDENCE - C2010089 (3)

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Marcia TaIvitie December 23, 2010 Page 2 % Pyritic Sulfur, Sulfate Sulfur, and Organic Sulfur in addition to Total Sulfur analysis. The reason for this is to be able to determine the Acid Mine Drainage potential of the replaced spoil material. In Table 2.04.6 -1 Coal Analyses and table 2.04.6 -2 Overburden Analyses of the application only Total Sulfur wt% is provided. Pursuant to Rule 2.04.6(2)(b)(i)(E), and the Division's "Guidelines for the Collection of Baseline Water Quality and Overburden Geochemistry Data" (Table 5 — Overburden Chemistry), please provide analysis information on the breakdown of the total sulfur, including sulfate, organic, pyritic and marcasite sulfur. 5. In the second paragraph of page 9 (fifth sentence) "...hole drilled..." should be plural "holes drilled ". 6. The footnote to Table 2.04.6 -2 indicates that trace elements were analyzed by EPA Methods 325216020. This should read EPA Methods "305216020 ". 7. The footnote to Appendix Table 2.06.6 -2 also has an incorrect reference to the EPA Method. Please make the appropriate corrections. 8. For the trace elements in Table 2.04.6 -2, the listings under Parameters/Units are confusing. Take Boron for example, it is shown as Tot. B, (Sol. B.), mg/kg. Please footnote and clarify what is meant by (Sol.) and provide the proper units for these analyses. 9. It is not clearly explained how the overburden analytical data are presented when comparing Table 2.0.4.6 -2 and Appendix Table 2.04.6 -2 with the laboratory analytical reports contained in Appendix 2.04.6 -3. There are numerous samples listed on the Iaboratory reports for East Nest, Northwest Nest, and Southwest Nest which presumably correlate to NA08 -E, NA08 -NW, NA -08 SW, respectively. There is no depth correlation to the data in either Table 2.04.6 -2 or Appendix 2.04.6 -3 and it is unclear how these correlate to the data provided in Appendix Table 2.04.6 -2. It appears that the data presented in Table 2.04.6 -2 are average values calculated from composite samples but this is not described or footnoted. Our "Guidelines for the Collection of Baseline Water Quality and Overburden Geochemistry Data" has specific recommendations for sampling each individual stratum and recommended thickness intervals for composite samples. The presentation of the analytical data for the overburden needs to be further clarified. Please ensure that all data presented in Table 2.04.6 -2 and Appendix Table 2.04.6 -2 is easily correlated with the laboratory analytical data presented in Appendix 2.04.6 -3. 10. Please provide the analytical laboratory reports for the data presented in Table 2.04.6 -2 for the five (5) overburden sample holes (1C, 3C, 695E, 697E and 775E) for which data are provided from New Horizon 1 Mine Area. This information should be provided in an Appendix to this permit application.