2011-03-14_REPORT - C1981008 (15)

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Spoil Quality The spoil sampling and analysis program recently approved with PR-06 for New Horizon • Mine is described in Section 2.05.4(2)(d)-4 Regraded Spoil Monitoring Program of Permit C-81-008. This plan will be implemented on next years (2011) sampling program due to the fact of all samples were collected prior to its final approval. The Soil Investigation completed by Walsh Environmental was limited to specific analytical parameters listed by the DMRS in a Notice Of Violation (NOV) CV-2010-003. Western Fuels implemented the soil testing programs immediately after their issuance from the Division and NRCS prior to the PR-06 approval. A new soil testing program with expanded field and analytical parameter was started in 2008 and is Attachment 2.05.4(2)(d)-1 Walsh Report on Subsoil Suitability in the current Approved Permit. The field and analytical parameters were further modified and expanded in 2010, therefore making some of the data appear to be inconsistent due to changing requirements at the time of that years sampling campaign. Attachment 2010-A contains the Walsh Soil Investigation in its entirety and gives greater detail on all sampling completed in 2010. Eleven (11) topsoil samples (TS), eight (8) backfill samples (NHSS), and 15 (fifteen) spoil samples (SS) for 2010 were collected from within the New Horizon 2 area. The NHSS samples taken on the prime farmland are included in this report for information only and do not reflect the newly approved subsurface soil sampling for the area south of BB road and west of 27 road. The SS samples taken on the prime farmland are in a much tighter grid (330ft x 330ft versus 600ft x 600ft) and with additional field and laboratory parameters. NHSS samples will continue to be employed in the remainder of the Permit area. Tables 2.05.4(2)(d)-1A and • 2.05.4(2)(d)-1 B in section 2.05.4(2)(d) Topsoil Handling, Stockpiling, and Redistribution, of PR-06 give reference to sampling parameters in specific soil zones for topsoil and subsoil. The soil samples were excavated with a backhoe, field described by a Soils Professional, than sent to various labs for the desired analysis. Topsoil sites are typically 0-2ft samples. Each NHSS sample site consists of two subsurface (below topsoil) samples; one is a 0 to - 2 ft interval, the other is a -2ft to -4 ft intervals. Sample identifiers are given the suffix A and B, respectively. The SS samples are 2ft samples taken at a depth of 3-5ft (below topsoil) and are limited to Prime Farmland area. Both topsoil and spoil samples were shipped to various laboratories for required analysis. The analytical results (Attachment 2010-A) indicate that all samples are suitable. No additional grading, special handling, or amendment applications took place in 2010. Soil Redistribution In general, the topsoil used for redistribution is live handled from ahead of the active mining area to the awaiting backfill area. Occasionally, mining parameters require that some topsoil be stockpiled adjacent to a laydown area prior to spreading. Currently the area south of BB Rd and west of 27 Rd (Morgan's proprieties) is handled in this manner. This area has 2 different topsoil zones that vary in thickness; A Lift (top) & B Lift (lower) and is considered to be prime farmland. These zones are striped and segregated into different stockpiles. These zones will be laid down in the same zone they were striped from; B underlying A. Also, there are required stockpiles of OB1 material further impeding Topsoil redistribution in that area. • F:\Eng\DATA\Word\Ann Reclaim Report\2010\2010RECRPT.doc 2