2011-10-24_REVISION - C1981008 (4)

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will be performed: 1) If the refusal occurs prior to the last quarter of the sampling a. A new sampling location will be resampled approximately one foot right of the previous sampling location. b. All previous obtained samples will be discarded and new samples will be collected for every sampling depth. 2) If the refusal occurs after sampling has begun for the last quarter a. The location will be sampled to the maximum depth possible and samples will be collected from the last quarter from the materials that is available. b. Total sampling depth of the location will be recorded. c. Information regarding the type of refusal that was encountered will investigated and recorded. Soil Suitability Criteria/Requirements This proposed revision application lists the chemical and physical parameters that the soil/overburden materials will be tested for. To enable an accurate and useful assessment of the degree of suitability of the materials sampled, appropriate suitability requirements must be established As previously discussed in OSM's above cited technical evaluation report, the suitability standards within the currently approved permit are inadequate for this purpose. Accordingly, the data collected from this proposed sampling study will need to be considered in concert with previously collected data from this site, to create new suitability threshold requirements for both the salvaged soils as well as all soil substitutes, on the Morgan property. The previously collected data would include the baseline data from the prior Peabody permit and the baseline data that is currently included within the approved permit. The development of appropriate soil /soil substitute criteria is necessary as a measure to determine the capability of the salvaged soils and soil substitutes for restoring the original prime farmland soil productive capacity. New soil and soil substitute criteria must be developed in consultation with the Natural Resources Conservation Service (NRCS) and must adhere to the guidelines established in Federal Register Notice 99- 16470. These guidelines state that the pH and other chemical properties of the major horizon of the reconstructed soil, must be within the ranges of the premined soil or be more favorable for plant growth. In short, the new suitability criteria will likely need to be similar to the characteristics of the prime farmland soils that existed on the Morgan property prior to mining. The soil chemical and physical parameters that will be sampled and analyzed for are based on USDA Forest Service User Guide to Soils (1979), the USDA Forest Service General Technical Report INT -68, and consultation with DRMS, NRCS (Natural Resource Conservation Service), and OSM. There does not appear to be any request from OSM for further sampling parameters, so no change has been made to the SAP parameters list. The SAP laid out in TR -61 is designed to gather data for the purpose of determining the best practices going forward in reclaiming the Morgan Property prime farmland. This will no doubt include a reevaluation of the soil suitability criteria in the permit. However, TR -61 is not intended to begin this reevaluation, and will remain confined to defining the Sampling and Analysis Plan as agreed by OSM, DRMS, NRCS, and WFC at the September 27, 2011 meeting.