REV15139

• Permit No: C1981041
• IBM Index Class Name: Revision
• Doc Date: 10/11/2006
• Doc Name: Preliminary Adequacy Review Letter
• From: DRMS
• To: J.E. Stover & Associates
• Type & Sequence: PR3
• Media Type: D
• Archive: No

PR-3 PRELIMINARY ADEQUACY REVIEW COMMENTS
General
There appears to have been a misstatement in the second sentence of the cover
letter to the PR-3 application; the reference to "industrial" postmining land use is
apparently erroneous. Based on information in permit approval documents and
Tab 15 of the current approved permit application, "Fish and Wildlife Habitat" is
the currently approved postmining land use for all disturbed areas in the Roadside
Portals permit area. Please confirm that this is the case, or provide basis for
the statement indicating that a postmining land use of "industrial" has been
approved for portions of the disturbed area.
2.05.3(3)(c) and 4.03.2 Access Roads
The grade of the proposed access road cut-slope ditch is 10%. No riprap or other
protection is prescribed in the revision documentation, and exposed soil would be
subject to erosion. The road itself is at 10%, and no wearing surface is specified.
Please provide designs for adequate ditch protection, and a wearing surface
on the access road segments that exceed grades of 3%, pursuant to
requirements of 4.03.2(1) and 4.27.3(7).
3. Please include the documentation required by 4.03.2(g)(ii) (written
landowner request), that the proposed portal bench access road be retained
for the postmining land use.
The application did not include road width specification required by 4.03.2(3)(c).
Section E2-E2' as drawn on Exhibit 6C should show the section but it is missing
from Exhibit 26. The road is shown in Sections L-L' amd M-M', but not at a
large enough scale to determine width or details oftoe-of--slope ditch. Please add
Cross Section E2-E2' to Exhibit 26 (in addition to the current listing in the
Roadside South Ditches table). Please include the road width, road
structure, and toe-of--cut ditch details.
Please address temporary erosion control measures (e.g. silt fencing, batting
logs, etc., along with location and duration of use) to be implemented during
and on completion of construction to minimize sedimentation and erosion
until a stabilizing vegetation cover is established on the slopes disturbed by
road construction, pursuant to 4.03.2(3)(d)(ii) and (e)(ii).
6. Rules 4.03.2(3)(e)(iv) through (vii) address various specifications for
embankment construction that were not provided in the application. Please
provide applicable design detail to address the requirements of
4.03.2(3)(e)(iv) through (vii), for the sub-grade, sub-base, and perhaps the
base course, of the road structure in the design and specifications for the
proposed access road.