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Section 2.05.3 Operation Plan — Permit Area <br />DRMSApril 2016 (New): Subsection Mine Bench <br />Paragraph 5 refers to the southeastern gully as a location of spoil material for utilization in reclaiming <br />highwalls and the drainage occupied by the Refuse Pile. DRMS understands this spoil to be located in <br />the area entitled: Plant Growth Medium Storage Area as depicted on Map King I-007. <br />Section 1.04(122) of the Board's Rules defines "spoil" as "overburden that has been removed <br />during surface coal mining operations ", with "overburden " being additionally defined at <br />1.04(83) as 'for surface coal mining operations, materials of any nature, consolidated or <br />unconsolidated, that overlies a coal deposits, excluding topsoil". Therefore, should the term <br />"spoil" as used by GCC be instead "Soil"? <br />2. Please update the text in this paragraph using the same terminology as on the map, referencing <br />the location ("southeastern gully') as the Plant Growth Medium Storage Area. <br />3. Please include the volume of stockpiled spoil (estimated by GCC Energy as approximately <br />16,940 cubic yards), in the discussion of this material in paragraph 5. <br />DRMS April 2016 (New): Subsection - Mine Waste Rock Disposal <br />Paragraph 1 of this section refers to Appendix 10(1) the Refuse Pile Design, prepared as a Report in <br />1998 by Mr. Don May. Paragraph 2 of this section states that Standard Proctor tests and nuclear <br />density tests will be performed as detailed in Mr. Mays report. <br />4. Is this report still relevant? If portions of this report have changed, please update any sections <br />of this report that may have become outdated. <br />5. Please incorporate in this section the density measurement criteria, specifically maximum dry <br />density, and the type of proctor test utilized, so that these details reside in the relevant section <br />of the permit as well as the appendix. <br />DRMS April 2016 (New): Subsection — West Waste Bank <br />Paragraph 3 of this section refers to Appendix 10(4) in the Trautner Geotechnical Report of June 2015. <br />The report comprises a series of evaluations and recommendations for the West Waste Bank and is not <br />intended to address all engineering or environmental requirements for meeting CDRMS regulations. <br />6. Please discuss and incorporate into permit section 2.05.3 those recommendations that will <br />reflect what is to be implemented "on the ground" as per design, stability criteria, and <br />hydrologic routing so that the permit reflects this information rather than residing as a series of <br />proposals in an appendix to the permit. <br />Prepared by: R. Reilley April 2016 <br />Relocation: M:\ Coal\ rar\ 1MKingCoal\ TR20 Page 1 <br />