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Limitations for use <br />Electrical Conductivity (dS /m)* <br />None <br /><0.75 <br />Some <br />0.76 - 1.5 <br />Moderate' <br />1.51 - 3.00 <br />Severe <br />? 3.00 <br />JoEllen Turner <br />970 - 864 -7682 p.3 <br />Borth Environmental Pollution Conspltlnq, LIZ October 2, 2012 <br />"This work was supported by funds from the State of Illinois, Amax Coal <br />Co., Southwestern Illinois Coal Co., Consolidation Coal Co.. Freeman <br />United Coal. Co., PeabodyCoal Co., Robertson and Associates, and the <br />Illinois Agric. Assoc." <br />3) What is the basis of your assumption that the Morgan property will behave similar to <br />other reclaimed soils - do you have long -term (10 -30 years) yield data for a similar reclaimed <br />soil? Based on the study by Stout 1998 (see above) only 41% of the PF fields had passed the <br />yield test in the 10 year liability period.... what type of sound science makes you believe that the <br />Morgan property will pass the yield test in the 1.0 year liability period? <br />4) Mr. Dunker strongly believes that WF has the technology and experience to successfully <br />reclaim the Morgan property. However be does not offer any evidence that WF has successfully <br />reclaimed (i.e., yield test passed within the 1.0 year liability period) sites at the Nucla mine. <br />5) Some of the reasons for me stating that it is difficult to predict if the property will <br />constitute prime farmland soil after reclamation are related to the following facts: <br />a) When. Prime Farmland topsoil and subsoil materials are stockpiled (stored), which <br />should ONLY be done when it is impractical to replace the material immediately on a regraded <br />area, then the stockpiles must be located away from potential contamination sources and must be <br />protected from wind and water erosion (Wade, S.L. and Kiehl, D.W., Illinois program <br />requirements, experience and results. Coal Research Ctr, Southern Illinois Univ: Carbondale, <br />1998; p 23 -30.). In the case of the Morgan property, dust or wind erosion of the stockpiles on <br />the property during the mining operation was managed by watering the property with <br />contaminated pit water with a conductivity in the range 4790 to 5480 uS /cm (or 4.79 to 5.48 <br />dS /m). In contrast the water that the Morgan's used for irrigation (CCC ditch water) had a <br />conductivity of approximately 0.34 dS /m (14 to 16 times lower than the pit water). The use of <br />high salinity water likely contaminated the stockpiles and the rest of the Morgan property in a <br />way that does not protect the Prime Farmland topsoil and subsoil from contamination. This also <br />explains why I observed salt crystals or salt precipitation on the surface of the stockpiles. For <br />reference I have inserted text from CSU Extension on Irrigation Water Quality (Fact Sheet No. <br />0.506): <br />Salinity Hazard <br />Table I. General guidelines for salinity hazard of irrigation water based upon conductivity. <br />*dS /m at 25° C = mmhos/cm <br />'Leaching required at higher range, <br />2 Goad drainage needed and sensitive plants may have difficulty at germination. <br />21 Page <br />PLTF 002476 <br />