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3. Revised pages 2.05-28 and 2.05-29 have blended the information rega~~ing reclamation of the <br />Waste Disposal Site and the No. 9 Portal Area Coal Refuse Disposal Site. These are two distinct <br />coal refuse disposal sites and the reclamation discussion previously has been discussed <br />individually in the permit. Please reinsert approved discussion regarding the Waste Disposal Site <br />back into the text. The Division includes the previously approved text along with this letler. <br />Response: The revised text has preserved the distinction between the No. 9 Portal Area, and the No. 9 <br />Coal Refuse Disposal Site. The text has been reorganized for clarity, however, careful comparison of <br />the previously approved text and revised text will confi*m that the original text content has been <br />preserved under the two separate headings; "No. 9 Portal Area", and "No. 9 Coal Refuse Disposal Site <br />(Approved)". Based on comparison of the previously approved and revised text, minor edits have been <br />made in the revised text for consistency. A copy of the revised text is provided with these responses <br />for reference. <br />4. Rule 4.11.4 requires that non-coal waste disposal sites be covered with a minimum of !wo feet of <br />soil cover. Revised page 2.05-30 only states that 6-12 inches of topsoil will be placed over the <br />final cover of the non-coal waste facility. Please provide a statement in this discussion that a <br />minimum of two feet of cover (topsoil or best available plant growth media plus spoil or other <br />cover material) will be used to cover the disposal site in accordance with Rule 4.11.4. <br />Response: Our review of the text (pages 2.05-29 and 30) indicates statements that BTU-EC will meet <br />the final cover requirements. To address the stated concern, however, the revised text has been edited <br />to include a specific commitment to placement of two feet of cover material. <br />5. Revised page 4.01-9, Section 4.11.4 references that non-coal wastes that meet the criteria of Rule <br />4.11.5 will be disposed of in the Solid Waste Disposal Area. Rule 4.11.5 references Dams and <br />Embankments constructed of Coal Mine Waste. The Division is not aware of any dams or <br />embankments on the Eagle Mine Complex that have been constructed of Coal Mine Waste. The <br />Division believes that this reference should read, "Rule 4.11.4". Please make the appropriate <br />correction on revised page 4.01.9. <br />Response: The inadvertent typo has been corrected. <br />b. For determining the reclamation cost estimate (RCE) BTU EC has not provided the dimensions of <br />the disposal area. The Division needs the dimensions of the excavation open at any one time in <br />order to determine the volume of cover material available. Please also state what the composition <br />of the seed mix to be used for the purpose of estimate. The permit has several seed mixes defined <br />in Tables. Reference to the appropriate table will allow the Division to determine the appropriate <br />reclamation cost. <br />Response: The initial submitted text indicated that the disposal site would contain 4.5 acres (400 x <br />500 feet). This equates to 200,000 sq. ft., which equates to 14,815 cu.yds. (@ 2 feet deep). Therefore <br />the volume of cover material required to cover the entire area of the Solid Waste Disposal Area is <br />14,800 cu.yds. <br />As shown on Map 29, Reclamation Plan Map, the area will be returned to cropland. The seed mix is <br />presented on Table 65, and indicates winter wheat @ 601bs/acre. <br />TR07-34 2 10/31 /2007 <br />