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Technical Revision No. 20 <br />March 3, 1995 <br />Page 3 <br />9. a. Please clarify the location of the west refuse ditch <br />prior to, during, and following construction of the <br />borrow area. As EFCI is aware, sediment control for the <br />refuse pile and borrow ditch must be in place at all <br />times, and until sediment control removal is approved. <br />Once the Swale is in place, it will become a natural <br />channel which will drain water coming off the pile and <br />from the swale itself. Sediment control ditches <br />associated with refuse piles are intended to be <br />temporary, while diversion ditches are intended to be <br />permanent. Is it EFCI's intention to make the ditch in <br />the Swale the permanent diversion ditch and eliminate the <br />diversion ditch located to the west of the Swale? Do <br />ground conditions facilitate this alternative? <br />Revised designs for the west refuse ditch at the toe of <br />the refuse pile and at the bottom of the Swale, and the <br />south refuse ditch have been reviewed. The ditch designs <br />were verified in SEDCAD and appear to be designed <br />adequately. <br />b. Based on the cross sections and plan view drawings of the <br />borrow area the Division would consider the borrow area <br />to be a valid reclamation plan for the refuse pile and <br />would meet approximate original contour. The Division <br />also concurs with EFCI's assessment that the regraded <br />Swale is consistent with post-mining drainage plans which <br />have been designed to divert runoff of and around the <br />refuse pile. <br />c. The Division concurs with EFCI's response. No topsoil <br />variance is needed as the replacement of six inches of <br />topsoil is consistent with the topsoil replacement plan <br />for the entire mine site and; therefore, does not deviate <br />from the approved reclamation plans. <br />10. As Map 7 has been revised to show the 35 foot rise on top of <br />the refuse pile, no further response is required. <br />11. The Division appreciates EFCI's survey of the current <br />topography at the loadout and will incorporate Map 30 into the <br />permit upon approval of this revision application. However, <br />revised Map 29 still does not show that the loadout will be <br />reclaimed to approximate original contour (AOC). From review <br />of the topography map, aerial photos, and site inspections it <br />is apparent that a ridge existed on the west side of the east <br />loadout. To return the east loadout to AOC, material which <br />was cut from this ridge and used to fill the east side of the <br />