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Deserado Mine; pg. 2 We also discussed the permittee documenting the 4 foot cover requirement on RA-1 by constructing soil pits for observation by DMG; and the permittee providing survey data for the amount of suitable soil material remaining in topsoiUsubsoil stockpiles at the RA-1 area The survey data should be provided as a part of the upcoming mid-term permit review which will be initiated by DMG on or about January 25, 1997. The permittee indicated this survey data was available for soil stockpiles at the other 3 refuse disposal areas and only RA-1 topsoillsubsoil stockpiles would have to be surveyed. Refuse pond (RP) 1 was completely dry as were ponds 4 and 5. Only pond 2/3 held a minimal amount of water. We continued the inspection at RA-2/3 by again walking the disturbed area. This pile contains wet areas due to both the nature of the refuse (included fine filter cake material) and the season of deposition. Mr. Matthews directed the permittee to work the pile as necessary in order to have the piles wet areas drained to the point where the pile can be graded and compacted as required before this coming winter. The permittee has been rotating refuse disposal between piles 4 and SA recently while RA-3 dries out. Technical Revision (TR) 39 which is currently being reviewed by DMG includes practices to reduce erosion on the active diversions draining the pile surfaces at all the refuse areas as well as plans to implement reclamation of constructed, permanent 100 yr. undisturbed area diversions. The most recent correspondence concerning TR-39 is a letter from DMG to WFU dated July 23, 1996, which requests further clarification of initial deficiencies noted in the TR submittal. Sediment ponds 2/3 and 4 were cleaned out last year and pond 5 is designed to contain the 25 yr. storm event. Two antelope were observed between pond 5 and the RA-SA refuse disposal area. We concluded the field inspection by walking the disturbed areas ofRA-4 and RA-SA. As mentioned above, these two areas have been utilized recently for refuse disposal on a rotating basis. Both areas were graded extensively during the recent idling of the mine. Compaction of the recently spread lift on RA-SA is ongoing. We discussed in the field at this location the permittee's intent to submit a TR within 2 to 3 weeks to combine RA-2/3 and RA-4. From field observations this appears to be a prudent idea to fully utilize available refuse disposal area. The current approved permit requires that RA-2/3 and RA-4 be reclaimed by 1996. The petTrtittee discussed that operationally since permit issuance and renewal that the operation has not generated the amount of refuse originally expected. In addition, the permittee now feels they will soon only process (wash) approximately 50% of the total coal production while still meeting contract coal quality obligations. This practice will generate even less refuse. As a result, the permittee has submitted as a part of TR-39 a revised schedule (Map 76) to complete the two refuse areas by 2004. As mentioned above, TR-39 is currently under review by DMG. The approved permit allows the three currently active refuse disposal areas to be open with total acreage "of about 120 acres." There does not appear to be any significant potential for off site impacts or limited reclamation success due to changes in the reclamation schedule proposed in TR-39. The operation is in compliance with the current permit requirements. In addition, TR-39 will require updated final reclamation contour maps of the active refuse areas.