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2016-04-29_REVISION - C1982056
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2016-04-29_REVISION - C1982056
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Last modified
8/24/2016 6:21:34 PM
Creation date
5/2/2016 2:15:14 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1982056
IBM Index Class Name
Revision
Doc Date
4/29/2016
Doc Name
Response to Adequacy #6 (E-mailed)
From
Twentymile Coal, LLC
To
DRMS
Type & Sequence
PR10
Email Name
JLE
DIH
Media Type
D
Archive
No
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downgradient of each disturbance area. Auger drilling is a dry drilling operation, so no mud pits were required, and <br />no discharge of drilling fluids occurred. Because the auger -holes and test pits were in reclaimed mine spoils on a <br />hillslope. the potential for intercepting any significant quantities of ground water was negligible. Air was not used <br />a circulation medium, so dust generation was not a concern. <br />Immediately following completion of sampling, each auger -hole and test pit was backfilled with excavated material <br />and leveled, with seeding of all sample sites following, either prior to snowfall, or in early spring when ground <br />conditions permitted. It should be noted that all minor surface disturbance associated with the site geotechnical <br />investigations falls within both previously disturbed areas, and the footprint of the proposed Refuse Pile Expansion, <br />and will be re -disturbed by Refuse Pile Expansion foundation preparation activities. <br />Design of the CRDA Expansion is based on design of, and operating experience gained from, the existing CRDA; <br />historic designs for a similarly -sized refuse disposal facility in the same location (CTL/Thompson, Inc., 08/14/92); <br />and site-specific topographic and foundation testing information. Design work for the CRDA Expansion has <br />included design of required foundation, perimeter, and surface drains by Hydro -Environmental Solutions, Inc.: <br />design of the required Coal Refuse Haulroad and refuse fills by Civil Design Consultants, Inc. and completion of <br />design stability analyses, and overall project management and coordination by NWCC. The designed CRDA <br />Expansion will contain a maximum of approximately 20.0 MM cy of refuse material, will be approximately 200- <br />250 feet high (relative to the existing terrain), and will be constructed with 3H: IV slopes with 20 foot intermediate <br />benches at 50 foot vertical intervals, resulting in overall slope angles of approximately 3.5H:1V. The CRDA <br />Expansion and associated facilities will re -disturb a total of approximately 140 acres of the existing refuse pile and <br />areas of reclaimed spoils. The upper surface of the CRDA Expansion will slope back to the southeast to prevent <br />drainage over the outslope, and a toe drain and designed perimeter drains will provide for drainage off of and under <br />the refuse fills. <br />Stability analyses of the proposed CRDA Expansion resulted in an overall Factor of Safety of 2.0, given <br />consideration of reasonable input design parameters. One of the key input parameters was the assumption that the <br />pile will be self -draining (based on experience with the existing RDA). In order to validate this assumption, TCC <br />will install three piezometers at the locations shown on the design drawings. Piezometers will be installed on <br />completed fill benches by drilling through the coal refuse materials and 5 feet into the foundation materials, casing <br />the holes with slotted 2.0 -inch Schedule 40 PVC pipe, with a sand pack and grout seal. The piezometer casing will <br />be protected by a PVC riser and a steel casing with lockable cap. Piezometers will be monitored monthly, and the <br />results will be included in the quarterly refuse pile reports. While stability analyses indicated that the overall <br />CRDA expansion would be stable, as designed, there is some potential for localized shallow surficial slope failures. <br />If shallow failures occur, they would be expected to be associated with moist fine materials, and would be <br />addressed by removing these materials and replacing them with compacted coarse materials. If such failures occur <br />with any frequency, the slope configuration may be modified or other measures implemented to minimize the <br />potential for future failures. Design documentation for the road and refuse pile design and stability analyses is <br />presented in Exhibit 26C, Coal Refuse Disposal Area Expansion. Designs for drainage structures associated with <br />the CRDA are presented in Exhibit 8EE — Coal Refuse Disposal Area Expansion — Drainage Designs. <br />Construction of the CRDA Expansion will be progressive, both from north to south, and with the pile increasing in <br />elevation, as dictated by refuse placement requirements. Construction will begin with implementation of temporary <br />erosion and sediment control measures, including placement of silt -fence and/or straw wattles downslope from <br />initial construction areas. Available soil materials will then be removed from the initial road corridor, drainage <br />channels, and refuse toe bench area (includes east -facing slope of existing RDA Area 1). It is anticipated that soil <br />material recovery will be extended, both to provide for approximately two years of scheduled refuse placement, and <br />to provide a reasonable buffer between the active construction and refuse placement activities and undisturbed <br />(reclaimed and revegetated) areas. Soil materials from the initial CRDA construction areas will be placed in <br />designated temporary stockpiles for future use in reclaiming completed CRDA benches or areas. Stockpile areas <br />will be accessed by either temporary scraper tracks or temporary haulroads within the CRDA footprint. As CRDA <br />construction progresses, the option will exist to live -handle the soil materials, with recovery from new placement <br />areas and direct placement on completed CRDA areas, or placement in/recovery from stockpile. To the extent <br />operationally practical, TCC will attempt to use live -handling practices in order to obtain the best reclamation <br />PR14-10 2.05-97.3 04/28/16 <br />
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