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precipitation and surface runoff, during waste pile construction. <br />13. Please add a narrative description and an illustration showing water routing to Section 2.05.3 of <br />the permit describing surface water drainage from the top and around the waste pile during its <br />construction. <br />Slope Stability Analysis <br />DRMS performed a slope stability analysis of the proposed West Waste Bank using GALENA - Slope <br />Stability Analysis System (Galena). Material properties and parameters used in the stability analysis <br />were taken from laboratory results from on-site samples as reported in Trautner's Report dated June <br />2015. The profile was mapped in Galena using the proposed Map King I -016A profile "A". For a <br />conservative approach, groundwater was included in the analysis at a level which is highly unlikely. <br />As noted in the Report, "Based on information obtained from our test boring advanced for this project <br />as well as several previous studies near the NKC 1 portal, we do not feel that shallow subsurface water <br />exists at the proposed West Bank mine waste deposit site." Results of the Galena stability indicated a <br />factor of safety of 1.83. This exceeds the minimum requirements of Rule 4.09.2(2). Factor of safety <br />results from Trautner's Report ranged from 1.87 - 2.60. Thank you. <br />Section 2.05.4 Reclamation Plan <br />DRMS April 2016 (New): Subsection: "Waste Pile Reclamation" (Mine Waste Rock Pile Reclamation) <br />The Trautner Geotech, LLC report of June 2015, in Appendix C, indicates that the waste bank will be <br />covered with 6-8" of high clay soil (rototilled into the waste) and 24" of suitable plant growth medium. <br />This is different from the reclamation plan for the refuse pile at King I proposed in Appendix 10(1), Mr. <br />May's Report and diverges from DRMS Coal Rule 4.10.4(5). <br />14. Please discuss why GCC is unable to comply with the requirement of Rule 4.10.4(5) to cover the <br />West Waste Bank with a minimum of 4 feet of the best available non-toxic, non-combustible <br />material. <br />15. If GCC wishes to receive approval of a request to cover the West Waste Pile with less than 4 feet <br />of cover material, please provide the required physical and chemical analyses demonstrating <br />that the requirements of Rule 4.15 (perhaps 4.15. 10(l) specifically?) will be met. <br />16. For the purpose of cost estimation, please provide the origin of the clay material and the plant <br />growth medium so that the Division can estimate the costs to haul and place this material on the <br />waste bank. <br />17. If the cover material for the waste bank will be borrowed from elsewhere on site, then for the <br />purpose of cost estimation, please provide a reclamation plan for the borrow area as well as a <br />drainage and sediment control plan to be implemented during excavation and reclamation of the <br />borrow area. <br />Prepared by: R. Reilley April 2016 <br />File location: M:\ Coal\ rar\ 1MKingCoal\ TR20 Page 3 <br />