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Tom Bird, GCC Energy <br />C- 1981 -035 / TR -20 PAR <br />29- Nov -2013 <br />Page 7 of 12 <br />Adequacy Comments regarding materials submitted with a0plication <br />Section 2.05.3 Operation Plan — Permit Area dated February 22 2013 <br />1. Subsection: "Mine Bench" <br />a) The 4h paragraph refers to a "back -filled gully ". Is this intended to mean the drainage <br />occupied by the permitted Refuse Pile? Please clarify the text. <br />2. Subsection: "Mine Waste Rock Disposal" <br />a) Throughout this section, the term "storage area" has been used to describe the areas <br />where permanent disposal of coal mine waste will occur. Please revise this section to <br />differentiate clearly between these three features: 1) the permitted valley -fill Coal <br />Mine Waste Disposal Area ( "Refuse Pile "); 2) the proposed "West Waste Bank" Coal <br />Mine Waste Disposal Area; and 3) the proposed "Coal Storage Area ". For each, it <br />will benefit the reader if consistent terminology is used throughout the permit. This <br />subsection should also reference the maps and appendices that contain the detailed <br />designs for the disposal areas. <br />3. Subsection: "Topsoil" <br />a) This section should be revised to also address any storage of "topsoil" or "cover <br />material ". <br />Section 2.05.4 Reclamation Plan <br />1. Subsection: "Grading and Backfilling" <br />a) The I" paragraph states, "... 6" of growth medium will be replaced on... the refuse <br />Pile." For clarification, please delete the reference to the refuse pile here; there is <br />potential for some confusion when comparing to the details provided in the "Waste <br />Pile Reclamation" subsection. <br />b) The 2 d paragraph was revised to include information on the proposed West Waste <br />Bank, while no changes have been submitted for the "Waste Pile Reclamation" <br />subsection. Please limit the portion under Backfilling and Grading to only that aspect <br />of the proposed West Waste Bank, and move all other discussion regarding the West <br />Waste Bank to the section addressing reclamation of Coal Mine Waste Disposal <br />Areas. <br />2. Subsection: "Waste Pile Reclamation" <br />