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ponding behind the seals, Please amend the reclamation plan to incorporate placement of pipes <br />to drain water collected behind the seals, and provide appropriately amended plans. <br />5. South Portal Drainage Plan issues. <br />a) Updated material balance calculations were provided on amended Exhibit 6C. Table 1J-1 <br />should be updated to correspond to the amended exhibit. <br />b) Appropriate cross-sections were provided. Comparison of amended maps and cross-sections <br />with photos and maps of the existing topography indicate that the proposed topography would <br />comply with backfilling and highwall elimination requirements of the regulations. Item <br />resolved. <br />c) Appropriate response and modified text was provided. Item resolved. <br />d) Appropriate response and modified designs were provided. Item resolved. <br />e) Appropriate response and amended text was provided. Item resolved. <br />6. Additional information and commitments regarding soil borrow area volumes, soil quality, and <br />topsoil salvage and replacement was provided as requested. It is not clear how the square foo_ tage <br />represented by each of the soil samples listed on new Table ld-7 was determined. Please <br />explain the basis for the projections, and provide the appropriate documentation. <br />7. The text was appropriately amended. Item resolved. <br />8. Appropriately amended Tab 20 text was provided as requested. Item resolved. <br />9. New Adequacy Items. In closely reviewing [he approved reclamation plan in association with <br />review of TR-35, we have identified the following issues of concern, which we request that you <br />address in the context of TR-35. <br />a) Steep slope seedbed preparation/soil roughening. No firm commitment is included in the <br />permit for scarification of the steep slope areas to be broadcast seeded, although on page 14-16 it <br />is stated that "...dozer tracking up and down steep slopes may be used before seeding to <br />establish a better seedbed." Based on results of previous seeding efforts on the CRDA refuse <br />piles where dozer tracking was employed, this technique would appear to be sufficient on north <br />and east facing slopes. However, on predom inaptly south and west facing slopes such as <br />CRDA 2 and portions of the RSRDA; larger scale, longer lasting roughening techniques would <br />be waranted, to provide for increased moisture retention and more favorable microsites for plant <br />establishment. An extensive gouging treatment accomplished by track hoe, as implemented <br />previously on the South Fan and 2-West Portal slopes, or similar gouging treatment applied with <br />a dozer blade, would be appropriate for the steep, unfavorable slope exposures. Please amend <br />appropriate section(s) of the reclamation plan to address specific seedbed preparation/soil <br />roughening techniques that will be applied to slopes prior to broadcast seeding. <br />b) Coal Creek Channel Permanent Diversion. An amended design for the permanent channel <br />diversion segment was approved by TR-32, which specifies removal of existing rock check <br />structures, salvage of channel sediment for use as non-toxic refuse cover, installation of riprap in <br />specified locations, and installation of concrete wingwalls a[ the upper road crossing. A <br />