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Susan Burgmaier -5- November 24, 2014 <br />• BRL reported 3.3 million tons of coal produced in 2013; information provided in the quarterly <br />refuse area inspection reports indicate that 844,429 tons of refuse were placed in the existing <br />refuse disposal areas in 2013. That suggests a ratio of roughly 255,888 tons of refuse generated <br />per 1 million tons of coal produced. <br />• In 2014, 1.4 million tons of coal were produced in the first half of the year, with 528,517 tons <br />of refuse placed. That suggests a ratio of roughly 377,512 tons of refuse generated per 1 million <br />tons of coal produced, with is a higher ratio of refuse to coal than observed in 2013. <br />• Based on the 2014 rate of refuse generation, just under 2.4 million tons of refuse <br />(3,068,041 CY, based on a conversion factor of roughly 1.3 CY of refuse per ton of refuse) would <br />be produced by the end of this permit term. <br />• The total design capacity of Gob Piles #2, #3, and #4 combined is 4,165,000 CY. Gob Pile #4 <br />has reached capacity. A generous estimate of the remaining capacity (combined) in Gob Piles #2 <br />and #3 would be approximately 1.5 million CY. <br />• Subtracting 1.5 million CY of remaining capacity in Gob Piles #2 and #3 from roughly 3 million <br />CY of refuse expected to be produced between now and April 2017 indicates that BRL needs to <br />provide a plan for on -site disposal, off - site - disposal, or both of approximately 1.5 million CY of <br />refuse. <br />Please provide a plan, in accordance with Rule 2.05.3(8), for the disposal of all refuse that will <br />be generated through the current permit term. If our estimate of refuse production and <br />estimated remaining disposal area volume is in any way incorrect, please let us know. <br />BRL - No response at this time. <br />17. Please update pages 2.05 -44 through 2.05 -49 and /or Map 9 of the permit application <br />package to include a comprehensive listing of all underground openings (drill holes, <br />boreholes, exploration holes, and wells) including the diameter and depth of each hole, the <br />area of each pad, and the length and width of each associated road, in compliance with Rules <br />2.05 and 4.07. <br />BRL - Please see new permit pages 2.05 -45i through 2.05 -45x. <br />Sincerely, <br />J. E. Sfov- r <br />J. E. Stover, P.E. <br />Consulting Engineer <br />Revised Pages: <br />Volume I: vii, 2.04 -11ii, 2.05 -8, 37, 38, 39, 41, 42, 43, 45i thru 45X, 46, 52, 62, 66, 67 and 106 <br />Volume IV: i <br />