2014-12-30_REVISION - C1996083 (5)

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William A. Bear Page 2of 3 December 30, 2014 WesTec report. Please annotatethe cover page of the 1996 WesTec report to indicate that a portion was revised with TR-97 (and with TR-64). Please also note the revision in that report’s entry in the TOC. (Modifying a portion of a document prepared and certified by another party is not generally done; at a minimum, any revisions should be re-certified by the party responsible for the changes.) 2. The 1999 Lambert report appears to address the question of stability for what is now known as Gob Pile #1. If this is the case, it would make better sense to include the new HBET Analysis in Volume IV rather than Volume IX, since Gob Pile #1 is covered byVolume IV, Gob Piles #2 and #4 are covered by Volume IX, and Gob Pile #3 is covered by Volume XI. Please consider whether the 2014 HBET Analysis should be located in Volume IVrather than Volume IX, and revise the Volume IV and Volume IX tables of contents as necessary. Volume IX Coal Mine Waste Disposal Area No. 2 3.Revised Page 18 was submitted with TR-97; it does not appear that there have beenany changes from the currently approved version of page 18 (approved under TR-94 in November 2014). If no revisions are proposed to page 18, this page should not be included as a proposed page in the TR-97 application materials. 4. A new paragraph has been inserted at the top of Page 19, referencing the HBET analysis dated Nov. 21, 2014. If BRL moves the HBET Analysis to Volume IV, this paragraph should be revised to direct the reader to Volume IV to locate the HBET analysis. 5. The Division received comments on the TR-97 application from the Mine Safety and Health Administration (MSHA), and forwarded those comments to BRL on December 17, 2014. The Division requested that BRL forward a copy of the proposed revision materials to MSHA and copy the Division on the transmittal. To date, the Division has not received a copy of correspondence indicating that the materials have been forwarded to MSHA. Please provide a copy of the revision materials to MSHA and provide a copy of the transmittal cover letter to the Division. In commenting on the application, MSHA cites 30 CFR 77.215(h), which outlines construction requirements for refuse piles. The rule states that slopes steeper than 2:1 (27°) may not be constructed unless approved by the MSHA District Manager. Approval of the MSHA District Manager for slopes steeper than 2:1 is not a specific requirement of the Division rules (Rules 4.11, 4.10, and 4.09) but, to avoid objections to any proposed decision by the Division to approve the revision, the Division will wait to propose a decision on the