2013-02-04_REVISION - C1981008 (3)

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JoEllen Turner 970 - 864 -7682 p.6 torch Environmental Pollution Consulting, LLC October Z 2012 In simple terms, it is not easy to establish a productive soil and it's even more difficult to predict if soil stored as stockpiles will make a good soil with high crop yields. If the soil is reclaimed with the best materials and methods it can become productive. However, in my opinion the best materials were not used (i.e., the substitute soil is not as good as the original soil) and the best methods were not used either (e.g., mixing of the A and B lifts). Similarly, the Bench One material has higher rock content than the original soils. I recommend since the substitute soils have already been spread with the rocks removal, as preferred above, will be impossible, I would suggest that an additional 19 inches of Barx soils be placed on top of the soil already in place for a minimum of 40 inches and that drainage is installed or an alternative effective desalination approach to ensure that the salinity of the reclaimed soil can be returned to levels of the original soil (2 dSlm or less). In Dunker's 2012 paper the following was stated in his introduction: "Most states require that success in re vegetation of crop land be determined on the basis of crop production from the mined land area as compared to either an approved reference area or to other technical guidance procedures. Statistical procedures may be utilized to determine productivity success. If a statistical approach is used productivity of the mined area shall not be considered equal (successful) if it is less than 100% of the production of the approved standard with 90 percent statistical confidence when planted to crops commonly grown, such as corn, soybeans, hay, sorghum, wheat, oats, barley, or other crops found on surrounding prime farmland. To demonstrate prime farmland productivity, the standards must be met in at least three crop years within a 10 -year period. Some researchers, coal operators and regulators feel a need exists for a method to evaluate reclamation in the absence of either test plots or actual measured yields. This would involve the development of indices to predict productivity of croplands after mining, on the basis of their physical and chemical soil characteristics.... Barnhisel et a1. (1992) looked at the development of a soil productivity index (PI) for use in prime farmland reclamation in the Midwestern cornbelt and collected data in Kentucky, Indiana, and Illinois. Soil parameters measured in this study included bulk density, cone penetrometer resistance, water- holding capacity, available P and K, exchangeable Al, particle size distribution, and pH. A four-year study was conducted to determine if corn yields could be predicted with the PI concept. Results were highly variable. Correlation coefficients between PI and yield ranged from near 0 to 0,76 from one field or mining method to another. Further refinement or weighting of components within the PI equation would be necessary to rely on a formula - based system to be used for bond release. However, the authors were not optimistic that this will result in a workable PI that would be able to consistently predict corn 51Page PLTF 002479