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• <br />• <br /> <br />Pertinent regulations require the installation of a pro- <br />perly designed subdrainage system to intercept all ground <br />water sources (Section 4.10.3 (1)(a)). A subdrainage system <br />is mandatory for coal processing waste banks (Section 4.10); <br />it is required only for valley fills (Section 4.09.2) if the <br />pile can be classified as excess spoil and underground devel- <br />opment waste (Section 4.09). <br />We recommend that the subdrainage system be eliminated <br />at the proposed waste rock pile for the following reasons: <br />1. There does not appear to be any ground water within <br />the colluvial soil underlying the proposed pile location. <br />Ground water appears to be at about the bedrock surface, at <br />least 30 feet below the existing ground surface.. There are <br />no seeps to be expected below the pile. This condition should <br />be further verfied by drilling of monitoring wells and by <br />long-term monitoring of ground water (if any) in these wells. <br />2. The waste pile certainly does not qualify as a valley <br />fill as it will be placed on a flat ridge between drainages. <br />3. The dimensions of the pile are limited. The width <br />of the eastern site is about 200 feet and the length some 400 <br />feet; the average corresponding dimensions .for the western <br />site are about 300 feet and 450 feet. The height of the pile <br />should not exceed 50 feet. <br />[de recommend that the following conditions be complied <br />with if the subdrainage system is eliminated: <br />1. The depth of ground water is verified by continued <br />monitoring during the period of snow melt and construction of <br />the pile, as discussed subsequently. <br />- 30 - <br />GE6NVDF0 CONSULTING. INC. <br />