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4.09.2—Valley Fill <br /> 4.09.2(2)(d) <br /> As originally stated in my memo dated May 3, 2019, "[p]er this rule...the <br /> Division has approved an alternative sizing with the currently approved <br /> underdrain...Please have King provide a demonstration or analysis that ensures <br /> the proposed underdrain expansion size is sufficient in alleviating water within <br /> the entire refuse pile including the proposed expansion per Rule 4.10.3(5)." <br /> In King's response (see GCC Reponses#6), they state that the currently proposed <br /> underdrain sizing is based upon the original refuse pile underdrain analysis in <br /> Appendix 10(1) and a July 2014 Trautner Geotech report. After reviewing King I <br /> PAP, I have been unable to find this July 2014 Trautner Geotech report and it has <br /> not been provided as part of TR-27. With that being said, from GCC's Response <br /> #6, it appears that the underdrain designed in the Trautner report is based on a <br /> considerably smaller pile expansion not specific to what is proposed under TR-27. <br /> To compensate for that change, it appears GCC used a linear relation between <br /> underdrain size and pile footprint area to size the proposed underdrain in TR-27. <br /> While this may be acceptable, this information needs to be updated and included <br /> with TR-27 for the Division's review. Please have King provide the July 2014 <br /> Trautner Geotech report and include discussions and/or"demonstration analysis" <br /> on the underdrain sizing for the currently proposed Lower Refuse Pile to comply <br /> with Rule 4.10.3(5). <br /> All other information required under 4.09.2 has been met. <br /> All other information required under 4.10.1 has been met. <br /> 4.10.2—Site Inspection <br /> Inspections of waste banks shall be conducted as per this Rule. No additional information <br /> is required. <br /> 4.10.3—Water Control Measures <br /> • 4.10.3(5) <br /> Please see comment under 4.09.2(2)(d). <br /> All other information required under 4.10.3 has been met. <br /> 4.10.4—Construction Requirements <br /> All information required under 4.10.4 has been met. <br /> 4.11—Coal Mine Waste <br /> Rule 4.11 is not applicable to the information proposed under TR-27. <br /> 2 <br />