2014-03-06_REVISION - C1996083 (2)

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Susan Burgmaier C- 1996 -083 TR -84 PAR 06 -Mar -2014 Page 3 of 5 As requested in Item 2 (32), above, BRL needs to provide a stability analysis for the proposed modifications to CMWDA #3 that considers undrained conditions, or justifies their being excluded from consideration. 3 (16) On Page 3 of Volume XI, please insert an entry for "Height: 120 feet" after "Slopes:" This item has been addressed. 4 (18) The revised Volume XI text includes pages 1 thru 4 and 5 thru 11. However, the current permit also includes pages 4a and 4b between pages 4 and 5. It is not clear, from this application, whether those pages are intended for retention under TR -84. Please clarify. This item has been addressed; pages 4a and 4b are not being removed or revised. 5 (20) Paragraph 2 of the Inspection section, on page 9 of Volume XI, refers to underdrains being covered with "excess spoil ". A term such as "coverfill" may be more accurate here? Please review and revise, if appropriate. Excess spoil was replaced by coverfill. This item is resolved. 6 (34) MLT 01/07: The Stability Analysis section on Page 11 of Volume XI refers to a Buckhorn report dated 26- Oct -2006, as does Buckhorn's 29- Mar -2007 report that was approved under TR -45. I am unable to find a copy of the 2006 report among the Division's records. Was this report officially approved under a specific revision? If it is not currently in the permit, this should be remedied. MLT 03/06: A copy of the 26 -Oct -2006 Buckhorn report was provided with the Feb - 2014 adequacy response. My review of the Division's permitting records indicates that this report was submitted with the original TR -45 application, which was deemed Incomplete. The 29- Mar -2007 report, which included a site investigation, was submitted later (effectively replacing the earlier version) and was subsequently approved as part of the permit. I recommend that the Oct -2006 report not be included in the permit, and that the permit text not reference that particular study. My original comment was in error regarding the Mar -2007 Buckhorn report's referencing of the Oct -2006 report. Instead, Buckhorn's list of references included a 15- Feb -2006 stability evaluation. That analysis was prepared for TR -42, which was later withdrawn. As discussed in the TR -85 review process, information provided in the 15- Feb -2006 Buckhorn report is foundational to a number of the later analyses. Because that report (Feb -2006) was prepared to address CMWDA #2, it should be incorporated into Volume IX of the permit. 7 (42a) Figure I of Volume XI has been revised to show the proposed reconfiguration of CMWDA #3 and proposed changes to topsoil storage. My only comment on this map is that the