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The Division is prepared to approve the underdrain as proposed, even though there is no indication <br />that one is needed or serves any :useful purpose. However, if seeps, springs and waterways are not <br />present and if BRL prefers, the application can be worded such that the site is to be inspected for <br />springs or seeps as work progresses, attd the drain installed only.for cause. This would be an <br />alternate design as permitted under Rule 4.09.1(3) and 4.10.3(5). <br />Please consider the under drain design to be a contingency, based upon the inspection of a certified <br />engineer ofthe prepared embankment footprint. Ifthere are no groundwater springs or seeps and no <br />natural drainage ways, then no under drain would be placed. If any are identified, the under drain <br />would extend from the toe of the embankment to the source of the seep. <br />The Division has no further concerns. Map 21-1, Map 21-3, Figure 1 and page 5 of Volume X[ <br />were revised in the January 3, 2007 submittal to show that an underdrain is not required. <br />23. Rule 4.!0.3(2) requires that any surface runofffrom the crest and face ofthe waste disposal area be <br />diverted in accordance with 4.09.2(7). However, the top surface ofthe pile as proposed is not diverted <br />as required. Please redesign the coal mine waste bank so that the top surface back-drains to ditches <br />D-J8-1 and D-J9-1 (see Map No. ]5-L, Sheet 1 of 4). The .1954 contour berm (Map 2/-1, Sheet 1 of4) <br />might be relocated to the crest of the bank. The purpose of this revision is to prevent surface runoff <br />from the top surface to flow over the face of the embankment, reducing the potential for erosion down <br />cutting into the mine waste materials. <br />BRL responded in the January 3, 2007 submittal that the curcent drainage configuration of the <br />refuse pile complies with Rule 4.09.2(7). However, the Division disagrees. Both Rules 4.09.2(7) <br />and 4.10.3(2) require such diversion, in addition to diversion of upland drainage as proposed and <br />cited. The Division cannot permit surface runoff flows over the face of a coal mine waste <br />embankment. Please provide for diversion of surface runoff from the fill surface as requested, <br />24, The material proposed to be temporarily stored in the coverfill stockpile is considered to be <br />underground development waste, per Rule 1.04(143) and, therefore, coal mine waste, per Rule <br />1.04(22a). Rule 4.10.3 for coal mine waste banks requires that an upland diversion ditch, <br />designed for the 100 year-24 hour precipitation event, 6e constructed. Please provide such a <br />design with appropriately revised pages and maps. <br />The Division has no further concerns. Because the coverflll stockpile is temporary and not a <br />permanent disposal site, Rules 4.09 and 4.10 do not apply. <br />Section 2.05.4, Reclamation Plan <br />25. The Division is in the process of calculating the reclamation cost estimate for TR-45. When the <br />cost estimate is completed, the Division wil! send a copy of the estimate to BRL. After review, <br />please inform the Division in writing whether or not the cost estimate is acceptable to BRL. <br />The review is still in progress. <br />