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<br />~ • <br />Westmoreland, inc. -4- <br />'monitoring system" maps in a manner that enables the reviewer to <br />ascertain the location and specific type (including details of samplin{; <br />and analysts) of monitoring conducted or proposed to be conducted. <br />jj. Pursuant to Sec[tun 784.11, provide furCher discussion of ventlla[lon <br />,y requirements and tdentl(y any needs Cor additional shafts and for tunnel <br />portals. It Ls sul;l;es[ed that modul[ng techniques, approved by MSIIA, be <br />employed Co determine op[Lnal ven[llation schemes for the mine plan area. <br />23. Pursuant to Section 784.11, explain the source and nature of material to <br />be placed in [he "Waste Disposal Area" (Map 13) and provide the necessary <br />physical and chemical analyses and the appropriate analyses of mass and <br />erosional stability. (See also Section 784.19.) <br />24. Pursuant to Section 784.]2, provide results of percolation tests in the <br />Crea[men[ plan[ oxidaClon pond. Provide water shed topography, and <br />specific calculations for the parking lot sedimentation pond. Maps 21 <br />and 17 do not join due [o [hc tack of scale nn Map 21. The calculations <br />provided in the Append lce.s are nnC adequate to evaluate compliance of the <br />exlstin~ sedlmenta[lon p,inds with the pcnnanont regulatory pros rem. The <br />pertinent calculations :should be presented in the Lext in a Ltgical <br />manner. Adequate data to enable selective checking by the regulatory <br />authority should be included. Show rolntionshlp between conduit <br />spillways and upper limit u( sedl.men[ storag.~ and ,ensure that durlnV; <br />dewatering, sedtmcnt Is not washed out. I'ruvlde Lhe results of surveying <br />of [here ponds (to present) in a forty lhnC fucilitates analysis of <br />sedtmcnt yields and deLiverius. <br />Provide additional information [ha[ show; why retention of the <br />sedimentation ponds will minimf a disCurbance [o [he hydrologic balance. <br />Explain [he handling of water discharged to thu area designated as "Waste <br />Disposal Arca." <br />25. With respect to SectLon 784.14, [he reclamation plan must be revised to <br />satisfy Che requirements of the sec~[lon. 'fhu plan has not adequately <br />addressed Section 784.13(b)(3), (4), (5), (7). Tlcc revegetatlon <br />conducted to date Ls not shown to be equal to the reclamation required by <br />Public Law 95-81. The proposal to retain the operational topographic <br />configuration as the postmining configuration is inadequately jus[Lfied. <br />The plan should address coverLng coal seems and partial backfllling and <br />grading of the benches ;uvl access roads and should contain analyses of <br />mass and erosional stabl.llty. There is na demonstration of the <br />feasLbiltty of the proposed postmtning land use, and the requirements of <br />Section 785.16 have not been met as yet by [tic application. CWI has had <br />discussions with the regulatory authority in this rc~ard and has received <br />some guidance regrndLng the necessary englnecrini; analyses. <br />~i . rahi 1,~,i ,fir, .it Y <br />~, <br />