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King Coal Mine (C-1981-035) <br />TR -20 Adequacy Review #3 Response <br />point (frequency of testing), the current permit is inadequate. Please update the permit to address <br />the frequency of compaction testing that will be conducted for both the West Waste Bank and the <br />Refuse Pile. <br />This item (frequency of compaction testing) does not appear to have been addressed in GCC's 06 -Oct - <br />2014 response, but can be incorporated into GCC's response to paragraph c), above. (Generally, <br />compaction tests are conducted at least quarterly, if any material is placed in a given quarter, and the <br />results are included with the quarterly report required by 4.10.2.). <br />King Coal: Section 2.05.3, page 3 now directs the reader to Section <br />6.5.1 of the Trautner report for inspection frequency and elements. <br />DBMS Oct 2015: Testing frequency has been adequately addressed. <br />DRMS Oct 2015: 1 have received the 6 July 2025 Quarterly Waste Pile Embankment Inspection (Quarter <br />2). The inspection notes limited placement of stockpiled material since previous inspection. The <br />inspection also notes that the placement of material should be periodically tested to ensure required <br />density/compaction is achieved as per design. <br />Please provide Quarter 3 Waste pile Inspection. <br />Also, please provide any results of the periodic density testing results of any stockpiled material that has <br />been placed. Density testing should include test dates and results. <br />7.0 Slope Stability Analysis <br />c) (New) GCC's 06 -Oct -2014 submittal included a Revised study by Trautner, dated 30 -Sep -2014. <br />The Slope Stability Analysis fails to incorporate the configuration evaluated by Trautnerin Feb -2013, <br />i.e. the pile height of 30 feet, with a 2.5:1 face. Now that the Trautner study has been updated, it <br />does not make sense to omit the proposed design from the Stability Analysis. Please update the <br />Revised study to include the proposed design configuration of the West Waste Bank. <br />King Coal: The Revised study by Trautner, dated June 29, 2015 <br />now includes the current proposed pile height and slope. <br />DRMS Oct 2015: irem resolved. <br />Permit Maps <br />d) The topsoil borrow area is shown, but the map should also show the cover material stockpile area. <br />Four plant growth medium storage areas identified in 06 -Oct -2014 response. The only description of <br />protecting topsoil storage piles is found on Page 14 of Appendix 11(1). Please revise the permit text to <br />include a description of measures that will be taken to protect stored topsoil, growth medium, or cover <br />material from erosion, in accordance with 4.06.3. <br />King Coal June 2015: Section 2.05.4, page 5A has been revised to include a description of measures <br />that will be taken to protect stored topsoil, growth medium, or cover material from erosion. A seed <br />mix to provide and effective cover of non -noxious, quick -growing annual and perennial plants to <br />stabilize and protect new topsoil piles has also been added to Section 2.05.4 page 5A. <br />Prepared by: R. Reilley October 2015 <br />File location: M:\Coal\rar\1MKingCoal\TR20 Page 5 <br />