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Susan Burgmaier C- 1996 -083 TR -84 PAR #3 02 -Jul -2014 Page 3 of 6 Summary that were transmitted to Bowie under TR -85 and will also be included in our second adequacy review for TR -84. 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. MLT 07102: As discussed under item 1 (32) above, HBET has satisfactorily addressed the question of Undrained conditions, and states it is unlikely that they will develop at Gob Pile #3 based on monitoring data from Gob Pile #2. HBET's report is silent regarding the acceptable range of moisture contents for placement and compaction. Buckhorn's Mar - 2007 recommendations still stand, and BRL's permit language does not commit to following those recommendations. The Rules do not address the question of moisture content, only the required level of compaction. 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 That analysis was prepared for TR -42, which was later withdrawn.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. MLT 07102: The revised Volume XI Table of Contents submitted on 12- Jun -2014 lists the Oct -2006 Buckhorn report. As explained in my 03106 comment, 1 believe that version was intended to have been replaced by the Mar -2007 report, and should not be included in the permit. 8 (44) MLT 03/06: The second bullet in the Assumptions section of the 15- Oct -2013 Buckhorn analysis states, "revised gob properties were derived from recent laboratory testing on consolidated gob material by ATT Laboratories ". Laboratory test results, particularly those upon which model assumptions are based, should be incorporated into the appropriate geotechnical report(s), as was done by Buckhorn in 2006 and 2007.