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Section 2.05.3 page 2 Mine Bench refers to spoil material located in the southeastern gully, estimated by <br />GCC energy to be approximately 16,940 cubic yards. This spoil is intended for reclamation of high <br />walls and the drainage occupied by the refuse pile. <br />18. As mentioned earlier in this letter, the term "spoil", as defined by the Board's rules, does not <br />seem applicable in this case. Should "spoil" be "Soil"? <br />19. Please provide information as to the anticipated volume of material required for reclamation of <br />these areas and include that information in the discussion of the reclamation in section 2.05.4 of <br />the permit. <br />20. If adequate material is not available for the reclamation of these areas, please describe where <br />additional material will be acquired. <br />According to permit section 2.05.4 page 5, Plant Growth Medium Dispersement and Grading, the spoil <br />stored in the Plant Growth Medium Storage Area depicted on map King 10 16 was analyzed at the <br />Colorado State University Soils Lab in 1994. The raw results of this analysis are presented in Appendix <br />12(3). <br />21. As mentioned earlier in this letter, should "spoil " be "soil "? <br />22. Please provide a short summary of the results indicating the suitability, drawbacks or soil <br />amendments necessary to make this material suitable for the reclamation purposes outlined in <br />section 2.05.4 of the permit. <br />The following item remains unresolved as per April 2016: <br />DRMS Oct 2015: <br />We are researching conclusions and recommendation for cover materials with respect to potentially acid <br />forming soils. In order not to exacerbate soil conditions (for example create a hard impermeable surface <br />between the acid forming portion and the transition soil), it is important to use the correct type of clay <br />and proportion of sand for the transition zone soil. Regarding the transition zone soil, we have the <br />following adequacy questions: <br />23. What type of clay is proposed for this area? <br />24. Please demonstrate that the proportion of sand and type of clay will indeed yield a transition <br />zone soil that does not create an impermeable layer between it and the potentially acid-forming <br />layer. <br />GCCE Dec. 2015: Appendix C of the Trautner report, "CDS Environmental Report", addresses <br />cover material and how it is to be placed on the West Waste Bank. Although the coal mine waste <br />material that was tested in this study has been moved to the Refuse Pile, it is expected that the <br />material which will be used to construct the West Waste Bank will be of similar composition. <br />Additional testing of the King II coal mine waste is addressed later in this letter and in new <br />Prepared by: R. Reilley April 2016 <br />File location: M:\ Coal\ rar\ 1MKingCoal\ TR20 Page 4 <br />