Letcher County FEIS Appendix G - Results of Investigation of Materials to be Excavated (2016).pdf

APPENDIX G

RESULTS OF INVESTIGATION OF MATERIALS TO BE

EXCAVATED (2016)

Results of Investigation of Materials to be Excavated at the Proposed United States Penitentiary and

Federal Prison Camp, Roxana Site Letcher County, Kentucky

January 2016

Prepared for:

United States Department of Justice Federal Bureau of Prisons 320 First Street NW Washington, DC 20534

Prepared by:

Ronald H. Mullennex, CPG, CGWP Senior Principal, Practice Leader - Geology and Hydrogeology Cardno, Inc.

534 Bluefield Industrial Park Bluefield, Virginia 24605 www.cardno.com

Results of Investigation of Materials to be Excavated at the Proposed United States Penitentiary and Federal Prison Camp, Roxana Site, Letcher County, Kentucky

Prepared for: US Department of Justice, Federal Bureau of Prisons

January 2016 Cardno, Inc. iii

Table of Contents

1 Introduction

1.1 Scope and Limitations

2 Site Location and Description

2.1 Location

2.2 Topography

2.3 General Geology

2.4 Previous Mining

2.4.1 Surface Mining

2.4.2 Underground Mining

3 Reconnaissance of Existing Water Quality

3.1 Field Reconnaissance and Water Sampling

3.2 Water Analyses

3.3 Water Chemistry

3.4 Historical Site Water Quality

Table 1: Summary of November 11, 2015 Water Quality Sampling

4 Investigation of Mine Overburden Material to be Handled

4.1 Overburden Distribution

4.2 Acid-Base Accounting Analyses

4.3 Overburden Material Characterization

5 Summary and Conclusions

6 References

Map 1 .............................................................................................................................................. Site Index Map

Biography of Writer

Appendices A ............................................................................................................ Permit No. 867-0298 Documentation B ..........................................................................................................November 11, 2015 Sampling Results C .............................................................................................................................. Stiff and Piper Diagrams D ............................................................................................. Water Quality Reports from 1993-1995 Period E .............................................................................................................. Geologist’s Logs of Drilling Results F ......................................................................................................................Acid-Base Accounting Results

Prepared for: US Department of Justice, Federal Bureau of Prisons

January 2016 Cardno, Inc. 1

1 Introduction

The Federal Bureau of Prisons (Bureau) proposes to construct a new United States Penitentiary (USP), Federal Prison Camp (FPC), and associated ancillary facilities on a property generally known as the “Meade Farm,” near Roxana, Letcher County, Kentucky. Cardno, Inc. is contracted by the Bureau to undertake and/or oversee research and investigations of the subject property to, among other things, develop and support an Environmental Impact Statement as to the proposed development.

The subject development is to be located on a former coal surface mine site that has been reclaimed. The existing ground surface at the planned construction site is immediately underlain by up to approximately 17 meters (56 feet) of broken, rubblized rock material residual to the mining operation. That unconsolidated material will generally need to be removed (to allow for the planned site construction) and re-placed in head-of-hollow fills at certain points around the construction site perimeter. Cardno’s Engineering and Environmental Services division (Cardno), mining advisory services group, has investigated the geochemical character of the rock rubble; and evaluated whether its further disturbance, removal, and re-placement is likely to induce material environmental impacts on the site and/or to streams receiving drainage from the site that could have significant bearing on human health due to the geochemical nature of the material.

1.1 Scope and Limitations

The focus of this component of the site investigation is to determine whether there is a likelihood of acid mine drainage (to include dissolution of metals of possible health concern) being generated by the handling and re-placement of rubblized rock material that is necessary for the planned site development. The investigation was conceived as a phased investigation, with the results of each stage dictating the need for or level of effort to be applied in a following stage. The scope of the commissioned investigation is an initial phase. However, as is discussed herein, the results are consistent and suggest that the investigation performed to date is adequate to serve the intent and purpose of the study. The investigation has involved: 1) sampling and analyses of existing water discharges from the site, most of which reflect water that has drained through the rubble material; and 2) collection, sampling, and analyses of the rubble material itself from multiple subsurface horizons at several locations within the area where construction and development are proposed. Additionally, site water quality information as documented in historical discharge monitoring reports associated with the surface mining permit, provided by the Bureau, has been compared to the recent data generated in this investigation.

In performing this investigation, Cardno has relied on information provided by others, including: historical water quality information from mine permit files, provided by the Bureau; a map of the boundary of underground mining provided in a report by Summit Engineering; and mine permit status information set forth in the Kentucky regulatory agency online-searchable database. Cardno has not attempted to verify the accuracy or completeness of such information, and makes no warranty as to such for information not generated by Cardno in this investigation.

The scope of investigation completed is consistent with that authorized by the client, and the approach and tasks performed are in accordance with accepted industry standards for the intended purpose. The consistency of results throughout indicate that a more intensive subsurface investigation is unlikely to produce significantly different results. However, no warranty or guarantee can be made as to whether a condition remains undetected by the extent of investigation conducted to date.

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January 2016 Cardno, Inc. 2

2 Site Location and Description

2.1 Location

The Meade Farm site, reportedly consisting of approximately 700 acres, lies on the south side of the North Fork of the Kentucky River near the small community of Roxana, Letcher County, Kentucky. The subject proposed development area is situated on the surface mined and reclaimed ridgecrest surrounded by the drainages of Tolson Branch to the west, North Fork Kentucky River to the north, and Kings Creek to the east. To the south, the subject site is bordered by the continuation of the ridgeline (see Map 1, in pocket following page 8).

2.2 Topography

The reclaimed surface mine site lies as a flattened ridgetop plateau at an elevation of approximately 460 meters

(m) (1500 feet [ft.]) above mean sea level (msl). To the east, north, and west of the plateau, the mountain slopes drop steeply to the streams situated at elevations of approximately 310 m to 330 m (1000 to 1100 ft.) msl, for a total local topographic relief of 130 m to 150 m (400 to 500 ft.). It is expected that the rubblized rock material that currently mantles the bedrock surface will be excavated to allow the building foundations to be placed on firm bedrock material. The excavated material, as shown on Map 1, is to be placed in head-of-hollow fills situated adjacent to the northwest and southwest of the proposed USP location. (The northwest head-of-hollow contains an existing fill that was constructed during the previous surface mining, but may have additional remaining storage capacity.)

2.3 General Geology

Surficial bedrock strata at the proposed building site are of the Breathitt Formation of Pennsylvanian age. These strata consist of clastic sedimentary rocks including, in general, sandstone, siltstone, shale and/or clay shale, and coal beds. Structural dip of the strata is very gently to the northwest at a magnitude of approximately 1.0 percent.

2.4 Previous Mining

2.4.1 Surface Mining

The subject site was surface mined by mountaintop mining methods in the late 1980s – early 1990s (Kentucky Department for Surface Mining Reclamation and Enforcement Permanent Program Permit No. 867-0298, issued December 31, 1987, effective date of license of April 29, 1988 – see Appendix A). The site has been fully reclaimed and requires no further monitoring or reporting, based on research of Kentucky Department of Natural Resources, Division of Mine Permits, Surface Mining Information System databases. The permit is identified as having been released in the Division of Mines’ Mine History Report for Cumulative Impact Area assessment (see Appendix A).

The surface mining involved the removal of up to about 60 m (200 ft.) of rock overburden to allow recovery of the Fireclay Rider (also known as Hazard No. 4 Rider) coal seam. Rubblized overburden material was re-placed onto the nearly horizontal coal seam pavement after the coal was extracted, and in three head-of-hollow fills located to the northwest, east, and southeast of the proposed facility (see Map 1). The depth of backstacked rubble on the reclaimed mine site ranges from nil to approximately 17 m (56 ft.), based on available exploratory drilling results.

2.4.2 Underground Mining

No underground mining is known to have occurred beneath the proposed locations of the USP, FPC, or the associated ancillary facilities. There is one small, long-inactive underground mine, in the Fireclay Rider coal bed, located to the south of the area of previous surface mining and planned subject development (Big Oak Coal Company, Kentucky Permit No. 867-5062). As can be seen on Map 1, the mine horizon is situated at an elevation of approximately 465 m (1525 ft.) above msl, and about 45 m (150 ft.) vertically upslope of the

Prepared for: US Department of Justice, Federal Bureau of Prisons

January 2016 Cardno, Inc. 3 proposed fill crest. The portal location was visited by Cardno, with the observation that there was no flowing water discharge on the day of the field visit, and no indication of any significant drainage at other times.

3 Reconnaissance of Existing Water Quality

The rubblized overburden generated in surface mining of the site in the late 1980s – early 1990s was placed back on top of the extracted coal seam horizon, and into three head-of-hollow fills around the mine perimeter.

Infiltrating precipitation percolates through the rubble and concentrates in the bases of the hollow fills, then migrates downslope in the subsurface to discharge at the toes of those fills. That water is in contact with the rock rubble, and its quality upon discharge is an excellent indicator of the geochemical nature of the fill material and of the quality of water that is expected to issue from the material after it has been excavated from the backstack area (the plateau) and re-placed into new or expanded perimeter head-of-hollow fills. Further, the acidity/alkalinity ratio and pH of the water is a principal control upon its ability to dissolve and mobilize “heavy” metals that could be of possible human health concern. As is discussed below in section 3.3, low-pH, acidic water is much more likely to mobilize most metals, while net alkaline, moderate-pH water is not likely to promote such mobilization.

As an initial planning step, topographic maps, aerial photographs, and mine maps were reviewed to determine likely or potential locations where flowing water may be sampled as an indicator of site geochemical conditions.

Features of note in that review include the three head-of-hollow fills, a fill toe pond at the base of the easterly fill, small stream segments downstream of the planned construction site, and the surface drift entry of the abandoned underground mine.

3.1 Field Reconnaissance and Water Sampling

Site hydrogeologic reconnaissance was conducted by a Cardno geologist on November 11, 2015. Water samples were collected from the toe discharges of each of the three hollow fills, the mouths of the two small streams flowing westerly from the site (one of which is below a hollow fill, and one of which does not have an upstream fill), and the eastern fill discharge after it has passed through the toe pond (see Map 1). The old underground mine portal was visited and confirmed to exhibit no surface discharge.

At each of the six sampling points, field measurements were recorded as to water temperature, pH, and conductivity. Samples were collected in four containers for each sample, placed on ice, and transported to the laboratory on November 13, 2015.

3.2 Water Analyses

The collected samples were transported to the main laboratory of Research Environmental & Industrial Consultants, Inc. (REIC), at Beaver, West Virginia, for analyses of general chemistry and metals. Specifically, the analytes and laboratory methods used were:

Analysis Analytes Method

Anions by Ion Chromatography chlorides, sulfate EPA 300.0, Rev. 2.1

Dissolved Metals by ICP antimony, arsenic, barium, beryllium, cadmium, calcium, chromium, copper, iron, lead, magnesium, manganese, potassium, selenium, sodium, thallium

EPA 200.7, Rev. 4.4

Total Metals by ICP chromium, iron, manganese EPA 200.7, Rev. 4.4

Dissolved Mercury mercury EPA 245.1, Rev. 3.0

Total Dissolved Solids TDS SM2540 C-1997

Total Suspended Solids TSS SM2540 D-1997

Acidity total acidity SM2310 B-1997

Alkalinity total alkalinity (as CaCO3) SM2320 B-1997 pH pH SM4500-H+-B-2000

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January 2016 Cardno, Inc. 4

Results of analyses are incorporated in Appendix B and discussed below.

3.3 Water Chemistry

Excavation and rubblization of rock strata has the potential to expose relatively fresh, unweathered rock to air (oxygen) and water, accelerating the weathering process by which rock minerals are dissolved and leached from the rock. Breaking of the rock also increases the surface area potentially exposed to air and water. Water infiltrating and passing through the rubblized rock transports dissolved mineral constituents, so that chemical analysis of that water is an indicator of the mineral composition of the broken rock strata.

Oxidation of sulfidic minerals produces acidic, sulfate-enriched (SO4) drainage. In the absence of acid-neutralization (alkalinity), the drainage tends to exhibit a low pH value1, and most metals are more soluble at lower, as opposed to higher, pH values. Where minerals containing substantial acid-neutralizing constituents are present (principally calcium [Ca] and magnesium [Mg] carbonate minerals, in the subject strata), the acidic drainage may be fully neutralized, resulting in pH values in the desirable 6 to 9 range. At that pH range, most metals exhibit a markedly lower solubility than they do at pH values below that range.

All of the waters flowing from the site are of a Mg-Ca-SO4 ionic facies, with elevated concentrations of magnesium, calcium, and sulfate, and with substantial net alkalinity (see Stiff and Piper diagrams, Appendix C).

All show influence of weathering of both sulfide and alkaline-rich minerals, such that any acid production has been completely neutralized by calcareous or carbonate minerals. These characteristics and the associated total dissolved solids (TDS) levels are likely representative of virtually all hollow fill discharges in the region as a whole.

The analyses results indicate there to be no concentrations of metals at levels of human health concern in water that has migrated through the rubblized rock material. While the water exhibits elevated sulfate and total dissolved solids concentrations (and consequent elevated conductivity) reflective of oxidation and dissolution of sulfidic minerals in the rock, it also contains net alkalinity with dissolved calcium and magnesium that, again, reflect dissolution of acid-neutralizing minerals. Acidity generated by oxidation of sulfidic minerals has been, in all cases, fully neutralized. The resulting water quality exhibits net alkalinity, pH values in the range of 6.73 to 8.11, and extremely low to non-detectable concentrations of metals of potential human health concern in occupancy of the site. Parameters that are often indicators of impacts from gas or oil well drilling (that is, reflective of deep saline waters) such as sodium, chloride, and barium are of quite low concentrations in the site discharges, indicating no impact in that regard from the existing gas wells that occur within the site (see Table 1 on page 5).

As is discussed further below, re-handling of the site overburden materials is likely to result in no significant change in the chemistry of water draining from the site.

3.4 Historical Site Water Quality

Mining permit-related historical water quality reports from the 1993-1995 period show results consistent with those of the recent sampling; that is, the waters exhibit net alkalinity, moderate pH values (6.34 – 8.17), and low iron and manganese, indicating likely low dissolved metals concentrations in general. (The data are enclosed in Appendix D, but specific sampling locations are undetermined.)

1 The pH value reflects the hydrogen ion activity level in a solution. It is expressed as the negative logarithm of that activity, such that the lower the pH value, the higher the hydrogen ion activity level.

The pH scale typically ranges from 0 to 14, and 7 is neutral (the point where hydrogen ion (H+) activity and hydroxyl ion (OH-) activity are in balance). Water quality standards typically reference a desired pH range of 6 to 9 (a common natural range) although normal rainwater is generally in the range of approximately 5 to 5.5 pH.

Prepared for: US Department of Justice, Federal Bureau of Prisons

January 2016 Cardno, Inc. 5

Summary of Water Quality November 11, 2015 Sampling

Table 1

Parameter Units

Southwest Stream Mouth

Northwest Toe Of

Hollow Fill

Northwest Stream Mouth

Southeast Hollow Fill

Toe

East Hollow Fill

Toe

East Hollow Fill

Below Pond

Field Temp ºF 50.8 54.1 54.5 54.9 55.4 55.9

Field Conductivity µmhos/cm 711 1,831 1,505 1,211 1,900 1,675

Field pH su 6.73 7.05 8.11 7.75 7.90 7.97

Lab pH su 7.22 7.41 8.31 7.89 8.09 8.23

Chromium mg/L <0.0010 <0.0010 <0.0010 <0.0010 <0.0010 <0.0010

Iron mg/L 0.0503 0.0854 <0.0100 <0.0100 <0.0100 <0.0100

Manganese mg/L 0.0162 0.0740 <0.0010 <0.0010 0.0061 0.0350

Chloride mg/L <0.20 3.95 2.34 1.93 3.02 2.26

Sulfate mg/L 316 1,210 794 763 1,310 1,030

Total Dissolved Solids mg/L 521 2,230 1,450 1,300 2,260 1,820

Total Suspended Solids mg/L <1 2 1 3 1 1

Total Acidity mg/L 10.9 32.9 <1.0 11 <1.0 <1.0

Total Alkalinity mg/L as CaCO3 51.1 377 215 191 308 270

Dissolved Antimony mg/L <0.0080 <0.0080 <0.0080 <0.0080 <0.0080 <0.0080

Dissolved Arsenic mg/L <0.0070 <0.0070 <0.0070 <0.0070 <0.0070 <0.0070

Dissolved Barium mg/L 0.0618 0.0335 0.0581 0.0373 0.0217 0.0277

Dissolved Beryllium mg/L <0.0002 <0.0002 <0.0002 <0.0002 <0.0002 <0.0002

Dissolved Cadmium mg/L <0.0003 <0.0003 <0.0003 <0.0003 <0.0003 <0.0003

Dissolved Calcium mg/L 63.5 259 181 155 250 207

Dissolved Chromium mg/L <0.0010 <0.0010 <0.0010 <0.0010 <0.0010 <0.0010

Dissolved Copper mg/L <0.0020 <0.0020 <0.0020 <0.0020 <0.0020 <0.0020

Dissolved Iron mg/L <0.0100 <0.0100 <0.0100 <0.0100 <0.0100 <0.0100

Dissolved Lead mg/L <0.0030 <0.0030 <0.0030 <0.0030 <0.0030 <0.0030

Dissolved Magnesium mg/L 54.7 234 178 153 238 216

Dissolved Manganese mg/L 0.0161 0.0502 <0.0010 <0.0010 0.0064 0.0293

Dissolved Potassium mg/L 3.42 13.2 9.14 8.87 16.4 14.3

Dissolved Selenium mg/L <0.0100 <0.0100 <0.0100 <0.0100 <0.0100 <0.0100

Dissolved Sodium mg/L 8.73 24.1 20.3 17.3 32.5 25.7

Dissolved Thallium mg/L <0.0090 <0.0090 <0.0090 <0.0090 <0.0090 <0.0090

Dissolved Mercury mg/L <0.0001 <0.0001 <0.0001 <0.0001 <0.0001 <0.0001

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January 2016 Cardno, Inc. 6

4 Investigation of Mine Overburden Material to be Handled

Six exploratory borehole drilling locations were specified by the Bureau (see Map 1). Drilling was conducted by Central Star Drilling, Inc., of Peebles, Ohio, using hollow-stem auger (HSA) and continuous split-spoon (SPT) sample collection techniques, under the supervision of a Cardno geologist. The geologist’s logs of drilling results are enclosed in Appendix E.

The rubblized overburden is a mixture of clay shale, siltstone, and sandstone. In each of the six boreholes, auger refusal was encountered a few meters beneath the apparent base of the rubblized backstack material, in weathered sandstone that appears to be representative of the uppermost bedrock surface. A total of 45 samples were collected from the six borings. Sample selections were made by the geologist with the intent of achieving fair representation of the rubblized material and weathered bedrock that would or may be excavated and re-placed into a fill.

4.1 Overburden Distribution

As is shown on Map 1, two borehole locations (Nos. 3 and 4) are within the central part of the site where the USP would be built. They encountered approximately 12 and 16 m (39 and 52 ft.) of rubble material, and extended into apparent weathered bedrock for another 2 to 5 m (6 to 16 ft.). Two boreholes (Nos. 5 and 6) located at the southern end of the site (general vicinity of the proposed central utility plant and outside warehouse) encountered about 13 to 17 m (43 to 56 ft.) of rubble and another 2 to 6 m (6 to 20 ft.) of apparent weathered bedrock. The two boreholes (Nos. 1 and 2) located on the northern point of the ridgeline (proposed FPC area) revealed no significant distribution of backstacked rubble there, and auger refusal was reached in weathered sandstone at depths of 3 and 4 m (10 and 13 ft.) below the ground surface.

4.2 Acid-Base Accounting Analyses

The 45 selected samples were delivered to Appalachian Laboratories, Inc., of Beckley, West Virginia, for acid-base accounting (ABA) analyses. ABA (EPA 600/2-78-054) is essentially a screening test designed to determine the relative proclivity for a material to produce either acidic or alkaline drainage, based on the potentially acid-generating and acid-neutralizing minerals present in the materials.

Acid generation in rocks of the subject area is due to oxidation of sulfidic minerals (most commonly pyrite) that releases acidity (hydronium ion, H+) and sulfate. Sulfur in the rock may occur as sulfate or as organic sulfur, but these forms do not produce acidity. It is common practice to perform a “total sulfur” analysis as the basis for an initial estimate (calculation) of the potential acid-generating capability of the material, and conduct further analysis of sulfur forms only where substantial acidity generation is suggested. This utilization of total sulfur as the basis for estimation overstates the actual acid-generating potential, and is thus conservative from the standpoint of identifying material that may produce more acidity than will be offset by its own neutralization potential.

The other principal component of ABA is the determination of acid-neutralizing potential. The majority of neutralizing potential (NP) is provided by calcium and/or magnesium carbonate minerals present in the rocks, although aluminosilicate minerals may also contribute to a typically small degree.

Material that contains a greater acid-generating than neutralizing potential is considered to be likely to produce acid drainage upon weathering, and low pH values resulting from the acidity favors the dissolution and mobility of many “heavy” metals during the weathering process. Conversely, material with more neutralizing than acid-generating potential is likely to produce neutral or somewhat alkaline drainage, which is not conducive to mobilization of those metals.

In addition to the determination of acid-producing versus acid-neutralizing potential, the ABA test procedures normally include quantification of the material color (a potential indicator of oxidation-reduction geochemical

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January 2016 Cardno, Inc. 7 conditions affecting the mineralogy of the material), a fizz (effervescence) rating (indicative of the degree and type of carbonate minerals present), and paste pH (indicative of the immediate tendency for acid or alkaline conditions to be formed).

Results of the ABA testing are enclosed in Appendix F and are discussed below.

4.3 Overburden Material Characterization

Results of the ABA testing show all of the sampled material to be quite low in sulfur content with very low potential to generate acidic drainage. Most of the material also exhibits only a mild neutralization potential (NP), and appears to be generally well-weathered material with relatively little remaining reactivity. There are a few scattered zones with greater than 2% total NP (as CaCO3), but none exceed 3% NP. Most exhibit total NP in the range of 0.6 to 1.5%, with net NP (NP less acid-generating potential) of 0.3 to 1.0%.

It is concluded that the material that may be excavated and re-placed is weathered, low-reactivity material with a consistent excess net neutralization potential in all samples. It would be expected to produce net alkaline drainage of circumneutral pH, similar to that currently discharging from the site. Based on both the water analyses and the ABA test results, there are no zones that require special handling, and there is very low potential for mobilization of metals of any concern to either human health or aquatic environments.

5 Summary and Conclusions

The proposed construction activities will entail excavation of rubblized rock overburden associated with previous surface mining, and placement of that material into new or expanded existing head-of-hollow fills. Some small amounts of weathered bedrock material may also be included in such handling. Investigation of the material shows it to be of low reactivity geochemically, exhibiting more acid-neutralizing potential than acid-generating potential (which is extremely low), and posing no significant risk of producing acidic drainage or drainage with significant levels of dissolved metals of concern as to human health in occupancy of the site.

The existing water chemistry in discharges from the fill structures is consistent with the findings of the subsurface materials investigation. The total dissolved solids contents of that drainage are elevated, reflecting the high degree of weathering that has occurred since mining and the continued flushing out of weathering-produced dissolved components, but the drainage is essentially devoid of heavy metal or trace metal components. The character of current drainage is similar to that which existed upon completion of mining, and that condition is not likely to be significantly changed by the excavation and the proposed site development to take place.

Although it was beyond the stated scope of investigation, it is noted that the current water chemistry indicates that there is no significant or detectable impact from deep saline waters that may have been encountered in installation of the gas wells that are present at the subject site. (Natural water present at depths commonly associated with gas well installations in the subject area is saline, with very high [relative to surficial or shallow groundwater] concentrations of sodium, chloride, and often barium. Those elements are not enriched in the current water discharges from the site.)

Prepared for: US Department of Justice, Federal Bureau of Prisons

January 2016 Cardno, Inc. 8

6 References

> Draft Environmental Impact Statement for Proposed United States Penitentiary and Federal Prison Camp, Letcher County, Kentucky, Federal Bureau of Prisons, February 2015.

> Preliminary Engineering Report, Addendum #1: Report Update, prepared by Summit Engineering, Inc., for Letcher County Planning Commission.

> Geotechnical drilling logs, drilling performed in August-September 2011, prepared by Marshall Miller & Associates.

> Kentucky Department of Natural Resources, Division of Mine Permits, Surface Mining Information System.

> Kentucky Division of Mine Permits (2011, July 14); Kings Creek – North Fork Kentucky River, Cumulative Hydrologic Impact Assessment (HUC12:051002010105).

Retrieved from: http://eec.ky.gov/SearchCenter/Results.aspx?k=867-0298.

> Geologic Map of the Roxana Quadrangle, Edward K. Maughan, US Geological Survey, 1976.

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January 2016 Cardno, Inc. 9

Roxana Prison Site, Letcher County, Kentucky

Map

BH-1-15

BH-2-15

BH-3-15

BH-4-15

BH-5-15

BH-6-15

Detail Undocumented

SW Stream Mouth

NW Stream Mouth

NW Toe of

Hollow Fill

East Hollow Fill Toe

East Hollow Fill Below Pond

(Pond Discharge)

SE Hollow Fill Toe

No Flow at Old Mine Adit

Big Oak Coal Co.

Mine No. 2

Fireclay Rider Seam

Site Index Map

DISCLAIMER: This map should not be used for mapping purposes or requirements under local, state, provincial or federal laws, regulations, or programs governing mine safety or environmental protection.

This map was prepared solely to assess coal reserves and resources and is based on information provided by others except as otherwise noted. Cardno has not surveyed the locations of mining, exploration holes, gas well, property control, permit boundaries, roads, or buildings shown on the map and does not warrant or otherwise certify the location of such mining (or absence thereof), or the other features depicted hereon.

Prepared for: US Department of Justice, Bureau of Prisons

January 2016 Cardno, Inc. 10

Roxana Prison Site, Letcher County, Kentucky

Biography of Writer

This page intentionally left blank www.cardno.com RONALD H. MULLENNEX Page 1 of 8

Current Position CPG, CGWP, Senior Principal, Practice Leader – Geology and Hydrogeology

Profession Professional Geologist, Certified Ground Water Professional

Years' Experience

Joined Cardno

Education MS – Geology, West Virginia University, Morgantown, WV BS – Geology, West Virginia University, Morgantown, WV

Professional Registrations

CPG

CGWP

PG – VA, SC, TN, PA,

KY, NC, GA

LRS – WV

WVDEP Approved Person for preparing, signing and certifying surface mine permit applications

Competent Person for coal resource determination under JORC Code

Summary of Experience

Mr. Mullennex is a Certified Professional Geologist and Certified Ground Water Professional with over 40 years’ professional experience in resource and mining geology, hydrogeology, environmental issues, and engineering applications. At Cardno, he directs geological and hydrogeological investigations, prepares and presents reports, and is frequently called upon in expert witness capacities in litigation concerning geological or hydrologic matters. He has authored a wide range of technical articles on coal resources, mining and mine drainage issues, groundwater and hydrogeology, environmental remediation, and geochemistry issues. He has also authored over 1,400 professional reports to clients in his consulting career.

A principal focus of his work in recent years has involved mineral resource evaluations and groundwater investigations in association with mineral extraction activities. Such groundwater studies include assessments of probable hydrologic consequences of mining; determination of existing and baseline hydrogeologic conditions; evaluation of hydrogeologic, geochemical, and geotechnical conditions and their potential impact on mining activities; and investigations of water quality and/or quantity impacts resulting from past mining or gas well drilling/operation. In mineral resource studies, his work has focused on resource distribution and classification, geologic factors affecting mineability and accessibility, and coal and tailings quality.

Mr. Mullennex earned Bachelor of Science and Master of Science degrees in Geology from West Virginia University in 1971 and 1975, respectively. He serves on the Visiting Committee for the Department of Geology and Geography at West Virginia University, and on the external advisory board for WVU’s Advanced Energy Initiative. He holds certification, licensing, and/or registration as a professional geologist in seven states, and is a Licensed Remediation Specialist under West Virginia’s Voluntary Remediation Program. He is a Competent Person in coal resource determination under the Australasian Code for Reporting of Exploration Results, Mineral Resources and Ore Resources (JORC Code).

Affiliations

American Institute of Professional Geologists Geological Society of America, Coal Geology and Hydrogeology Divisions Society of Mining Engineers of Association of Mining, Metallurgical, and Petroleum Engineers Sigma Gamma Epsilon (Earth Sciences Honorary Fraternity) Association of Ground Water Scientists and Engineers, Division of National Ground Water Association Association of Engineering Geologists American Society of Mining and Reclamation International Mine Water Association

Ronald H. Mullennex www.cardno.com www.cardno.com RONALD H. MULLENNEX Page 2 of 8

Significant Projects

> Explore and evaluate geologic, hydrogeologic, and geochemical issues pertaining to large coal exploration, mine planning, and Definitive Feasibility Study (DFS) in virgin area of Western Australia, including water supply, mine inflow, water quality, and materials handling investigations, and delineation and assessment of resources and classification under JORC.

> Joint coordinator and principal investigator in compilation of environmental audit for World Bank affiliate, for large mining project in the People’s Republic of China.

> Expert Witness in litigation and regulatory administrative proceedings. Qualified as expert in hydrogeology, geology, hydrology, water quality, and geomorphology.

> Evaluate sources, extent, and nature of impact of selenium leaching from mine disturbances into receiving streams and develop mitigation through water management and enhanced passive reduction-adsorption processes.

> Site characterization, monitoring, and implementation of enhanced bioattenuation remediation program in fractured bedrock aquifer.

> Hydrogeologic investigations of potential hydrologic consequences (PHC) by mining operations (numerous studies, some involving large areas).

> Hydrogeologic and geotechnical evaluations of conditions to be encountered, potential hydrologic impacts, and design of preventive measures for advancement of underground mines beneath stream valleys (numerous studies).

> Investigated and served as expert in litigations concerning natural flow, transference, and water chemistry of brackish and saline waters from deep underground mine.

> Water chemistry and contaminants investigations of alleged impacts to groundwater by gas well drilling and/or operations.

> Investigations and assessments of causative and contributory factors regarding landslides, subsidence, and flooding events, including geomorphological analysis of features.

> Hydrogeologic investigation and development of during-construction monitoring and preventive action to prevent adverse grout migration through the aquifer during mine shaft pre-grouting and construction project.

> Assessment of potential impact of high-extraction underground mining upon stream conditions, and worked with mine design engineering personnel to devise alternative mine plan to avoid impact to stream.

> Investigation of acid-producing rock materials and acid drainage for large highway construction program, and work with design engineers to develop materials handling plans, drainage structures and treatment plans.

> Hydrogeologic and geotechnical investigation of large pre–Subtitle D landfill located in karstic terrain to evaluate impact on environment and develop plans for closure.

> Remedial Investigation and Feasibility Study of a state superfund office site, involving ground water impact by dissolved trichloroethane and related compounds in fractured bedrock aquifer. Coordinated and critiqued baseline risk assessment.

> Served on Tazewell County, Virginia, Comprehensive Plan Committee, assessing karst impacts and ground water concerns for land use planning.

> Developed numerous Subtitle D landfill groundwater monitoring programs for solid waste and CDD facilities, and managed the implemented programs; to include sampling, analyses, data evaluation, and reporting.

> Development of landfill gas migration mitigation measures at sites complicated by karstic conditions and by underground mine workings.

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Significant Projects (Continued)

> Utilized ground water modeling to design extraction/injection system for aquifer remediation.

> Hydrogeologic assessment, aquifer testing, groundwater modeling, and expert witness testimony concerning DNAPL–related contaminants in bedrock aquifer.

> Hydrogeologic investigation of impact of abandoned underground coal mine on adjacent stream and residential water supplies; developed successful remedial plan, and monitored results.

> Investigation of impacts to hydrologic regime resulting from underground mining in areas beneath stream valleys.

> Investigation and delineation of impacts and design inadequacies of several solid waste landfills for closure design. Led design team of geologists, hydrogeologists, and engineers in completing closure designs, and acted as Principal Investigator in the investigation and design phases.

> Served as Principal–in–Charge of Construction Quality Assurance/Quality Control and field inspection for landfill closure construction projects.

> Hydrogeologic investigation and litigation support in alleged salt impact to shallow groundwater.

> Supervision and peer review of numerous investigative reports involving leaking underground storage tanks and similar contaminant releases to ground water.

> Detailed investigation of geologic factors controlling or influencing coal resource distribution and development potential, with analysis of potential hazards to be encountered in longwall mining.

> Detailed depositional analysis and interpretation of coal resource distribution and factors impacting future development.

> Regional investigation and exploration of deep coals.

> Stratigraphic analysis and interpretation of depositional patterns responsible for producing extreme hazardous conditions encountered in mining.

> Exploration and delineation of coal resources; prediction of mine roof hazard areas.

> Exploration and delineation of stone resources and stone geochemical characteristics.

> Detailed investigation and interpretation of small–scale depositional features impacting coal reserve development.

> Study and interpretation of paleogeographic and depositional conditions controlling resource distribution in several different coal seams.

> Geologic investigation and expert witness for properties and mining ventures involved in prosecution in Federal court.

> Management of active oil and gas leaseholds.

> Evaluations of oil and gas estates involved in condemnation.

> Reserve and economic development feasibility evaluation of several thousand acres in widely scattered tracts. Served as expert witness in civil proceedings in Federal Tax Court, with beneficial results to client.

> Mapping, investigation, and evaluation of geologic, hydrogeologic, and geomorphic features relevant to new highway construction.

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Significant Projects (Continued)

> Investigation of ground water contamination susceptibility of a regional area involving largely karstic limestone and dolomite bedrock, incorporating assessment of multiple geologic and cultural components to delineate relative hazard potential at any point within the area. Study involved evaluation of stratigraphy and lithologic factors, structural geology, soil types, remote sensing analysis of fracture systems, water table levels, ground water flow directions, recharge and discharge areas and points, and investigation of ground water communication between wells. Results used for determining relative need for sewerage construction at different points within study area.

> Investigation of karst sinkhole subsidence and triggering mechanisms, pertaining to damage to existing structures.

> Utilization of geologic evaluation and remote sensing analysis to locate high–yield water wells for municipalities and industries.

> Consultation to an engineering firm regarding dye–tracing applications to define ground water flow characteristics.

> Determination of karstic controls on ground water in evaluation of suitability of construction site.

> Conducting geologic evaluations and remote sensing analyses, and integrating these studies to define potential ground water flow characteristics that may impact underground mining.

> Supervision and analysis of packer testing techniques to determine permeability of formations in boreholes.

> Utilization of geophysical logs to identify ground water flow characteristics encountered in boreholes and select optimum horizons for piezometer installation.

> Utilization of geophysical logs and analytical data to define geochemical characteristics of rock and coal strata.

> Site evaluation of a planned large commercial landfill facility encompassing in excess of 500 acres. Acted as project manager for field activities including planning and executing of 58–borehole geologic and hydrogeologic exploration program;

access road construction in very rugged terrain, with associated sediment and erosion control; and installation of single and nested piezometers and monitoring well construction. Performed analysis of geologic, geophysical, and hydrogeologic data to evaluate suitability of site, and determined post–construction monitoring requirements in relatively complex hydrogeologic setting. Acted as primary coordinator for report and permit application preparation, incorporating investigative reports from other consultants into a comprehensive permit application package.

Professional History

2014 - Present Senior Principal, Practice Leader – Geology and Hydrogeology

Cardno, Inc. – Bluefield, Virginia (USA)

Responsible for office management and administration; project management, coordination, and supervision; and project reporting and presentation. Is Cardno’s corporate officer member of the Radiation Safety Committee and provides management oversight of the company’s geophysical logging division.

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1979 - 2014 Senior Vice President

Cardno, Inc. (formerly Marshall Miller & Associates, Inc.) – Bluefield, Virginia (USA)

Responsible for office management and administration; project management, coordination, and supervision; and project reporting and presentation. Provided management oversight of drilling services division for several years. Projects involve all phases of geologic application to coal exploration, evaluation, and development in the United States and abroad; quarry stone resources and stone quality; construction and environmental site characterization; ground water and surface water investigations;

investigation of mining and hydrogeologic considerations in the United States and abroad; underground injection permitting and impact assessment; and writing of technical reports. Specific experience includes coal and geologic mapping; mineral property evaluation; management and supervision of exploration programs; study of geologic factors in resource minability (geologic hazards, depositional analyses);

initiation and utilization of stratigraphic and depositional environmental studies as applied to exploration and development; ground water availability, contamination, and monitoring studies; investigation of karst impacts on environmental considerations;

utilization of remote sensing techniques, including lineament and fracture analyses;

development of ground water monitoring strategies and systems for solid waste landfill facilities; assessment of monitoring data to determine impacts; coordination of full site investigation and remedial design teams for landfill closures and sites impacted by volatile organic compound contaminants in ground water; investigations of hydrologic impacts resulting from mining; risk assessment and development of remediation designs for ground water contamination; development of mitigative measures for landfill gas migration; geomorphic evaluations of flooding and earth movement issues, and serving as expert witness in cases concerning mineral properties, ground water, and flood analysis.

1977 - 1979 Project Geologist

Geological Consulting Services, Inc. – Bluefield, Virginia (USA)

Responsible for field and in–office project management, coordination, and supervision.

Projects involved primarily coal property exploration and evaluation.

1974 - 1977 Coal Geologist, West Virginia Geological and Economic Survey

West Virginia Geological Survey – Morgantown, West Virginia (USA)

Responsible for mapping, data collection, and correlation of coals in regional study of coal resources and development potential.

Publications & Presentations

> “Selenium – Sources and Considerations for Treatment or Prevention” Wastewater Treatment and Water Quality for Indiana Coal Mines Workshop, 26th Annual Surface Mined Land Reclamation Technology Transfer Seminar, Jasper, Indiana, December 9, 2013.

> “A Cost-Effective Approach to In Situ Bioremediation in Fractured Bedrock,” The Ninth International In Situ and On-Site Bioremediation Symposium, Baltimore, Maryland, May 7-10, 2007.

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> “Stratigraphic Distribution of Selenium in Upper Kanawha-Lower Allegheny Formation Strata at a Location in Southwestern West Virginia,” 22nd Annual International Pittsburgh Coal Conference, Pittsburgh, Pennsylvania, September 14, 2005.

> “The Floods of July 8, 2001: A Review of Characteristics, Distribution and Contributing Factors,” Virginia Center for Coal and Energy Research and the Central Appalachian Section of SME, Abingdon, Virginia, April 2002.

> "Subsidence Impacts on Ground Water," Virginia Center for Coal and Energy Research and the Central Appalachian Section of SME, Abingdon, Virginia, June 2000.

> “Recognition of Paleosols From Wireline Logs,” Predictive Stratigraphic Analysis Workshop, U.S. Geological Survey, Reston, Virginia, April 1996.

> “Mitigation of Environmental Impacts Resulting From Mine Pool Build–up,” Mine Drainage Task Force Symposium, Morgantown, West Virginia, April 1996.

> “Integration of Hydrogeologic and Geophysical Techniques for Identification of AMD Seepage and Remedial Design,” R.H. Mullennex, C.P.G., C.G.W.P., V.P. Wiram, C.P.G., H.E. Naumann, P.E., Mine Drainage Task Force Symposium, Morgantown, West Virginia, April 1995.

> “Remedial Measures,” Business and the Environment Seminar, Bluefield, West Virginia, July 1993.

> “Hydrogeology of the Appalachian Plateau,” Ground Water Hydrology, Contamination and Management: Wellhead Protection in the Appalachian Plateau, USEPA and Cook College of Continuing Education, National Mine Safety and Health Academy, Beckley, West Virginia, June 1993.

> “Remedial Measures: Planning and Managing Closure and Post Closure Activities at your Sanitary Landfill,” Business and the Environment Seminar, Bluefield, Virginia, 1993.

> “Downhole Camera Brings Visible Benefits to Ground Water Monitoring,” World Wastes, Vol. 35, No. 12, December 1992.

> “Ground Water Monitoring at Sanitary Landfills – Sampling and Analysis Considerations Under Subtitle D,” World Wastes, Vol. 35, No. 6, June 1992.

> “Ground Water Monitoring at Sanitary Landfills – System Design Considerations Under Subtitle D,” World Wastes, Vol. 35, No. 2, February 1992.

> “Water–Bearing Fracture Identification Through High–Resolution Density Logging Techniques,” presented at National Water Well Association Exposition Forum on Ground Water Technologies for the 1990's, October 23, 1991, Washington, D.C.

“Ground Water Issues,” Business and the Environment Seminar, Bluefield, Virginia, 1991.

> “Geological and Environmental Impact on Development and Construction in Our Area,” Business and the Environment Seminar, Bluefield, Virginia, 1991.

> “Preparing for an Environmentally Safe Landfill,” Business and the Environment Seminar, Bluefield, Virginia, 1991.

> “Lithologic Indicators of Geochemical Conditions of Sedimentation in Pennsylvanian Age Rocks of the Appalachian Basin,” C. Blaine Cecil, U.S.G.S.; Ronald W.

Stanton, U.S.G.S.; and Ronald H. Mullennex, Geological Consulting Services, Inc.;

American Association of Petroleum Geologists Symposium, Charleston, West Virginia, September 1988.

> “Geological Modeling Techniques for Evaluation of Productivity–Related Longwall Mining Roof Conditions: A Case Study,” Longwall U.S.A. Conference, Pittsburgh, Pennsylvania, co–author, September 1988.

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> “Prediction of Coal Continuity, Quality, and Mining Conditions as Afforded by Depositional Analysis,” Society of Mining Engineers of AIME, Fall Meeting, St. Louis Missouri, 1986.

> “Use of Depositional Models and Stratigraphic Mapping Techniques to Determine New Coal Reserve Potentials in the Appalachian Region,” AIME Annual Meeting, Chicago, Illinois, published in Transactions, the permanent technical literature of the Society of Mining Engineers of AIME February 1981.

> “No. 3 Pocahontas Coal in Southern West Virginia – Resources and Depositional Trends,” West Virginia Geological Survey Bulletin B–38, co–author 1981.

> “Case Histories and Depositional Modeling for Classifying Reserves in the Appalachian Region,” Miller, M. S., and Mullennex, R. H., American Association of Petroleum Geologists Meeting, Morgantown, West Virginia, October 1980.

> “Major Cross–Strike Structures of the Central Sedimentary Appalachians,” Proceedings of the West Virginia Academy of Science, Vol. 46, No. 2. , 1974.

Continuing Education > Passive Treatments for Sulfate and Metals in Mine Water, American…