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New Elk Coal Company <br />IV <br />d. Culvert C 17 is designed to convey the flow of the upper reach of D22, and is <br />sized appropriately. Since the lower reach of D22 conveys a greater flow than the <br />upper reach (and will convey more pending the approval of this revision) the <br />lower reach should be re- designated in order for tables 20 and 21 to remain <br />consistent. Please re- designate the lower reach of D22, updating table 20 and Map <br />13 as necessary. <br />NECC - The lower reach of D22 will be renamed D22A. <br />e. Culvert C22 will be affected by the new culvert C 19. Although C22 is approved <br />as a temporary culvert to be installed as necessary, it should be sized <br />appropriately if it is installed. Please include a design for C22 and update table <br />21. <br />NECC - A design is included for C22. Exhibit 19(25) was completely revised. <br />8. DRMS- The changes proposed under TR70 infer the intention of the NECC to <br />transport development waste from the approved temporary and permanent storage <br />areas to the RDA. A demonstration must be made that the material properties of the <br />development waste are such that when it is deposited on the existing pile either alone <br />or when mixed with processing waste the design of the RDA will not be <br />compromised. Please provide documentation to support the deposition of <br />development waste on the RDA, and amend the permit text to describe any proposed <br />changes to operational procedure. <br />NECC - Amended page 2.05 -43 provides a demonstration that the material properties <br />of the development waste are such that when it is deposited on the existing pile either <br />alone or when mixed with processing waste the design of the RDA will not be <br />compromised. <br />9. DRMS - Exhibit 28 (Reclamation Cost Estimate) should be updated to reflect the <br />increased reclamation cost resulting from the proposed new structures. Please submit <br />a revised RCE or state that you wish the Division to update the RCE. <br />NECC - Please have the Division update the RCE. <br />Sincerely <br />Louis Head <br />Secretary <br />