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2 2. Paragraph 3, page 3 of AFO's letter, referring to a DMG memo, says, "the memo states: '***that currently revegetated portions of the pile meet cover and production success criteria during the 9th and 10th years of the bond liability period "'. This indicates it is DMG's position that cover and production standards have been met on portions of the pile. In fact, the DMG memo says, "For the Roadside pile, I would recommend that we conditionally approve the 6 inches cover depth, with the provision that currently revegetated portions of the pile meet cover and production success criteria during the 9th and 10th years of the bond liability period." The DMG memo does not indicate that portions of the pile have meet success criteria, as indicated in the AFO letter. 3. Paragraph 1, page 4 of AFO's letter mentions that DMG's response to the TDN did not address field problems outlined in the inspection report. DMG's response addressed the issue of contemporaneous reclamation cited in the TDN. Other problems outlined in the inspection report were not included in the TDN and are not directly relevant to the question of contemporaneous reclamation. Therefore, they do not need to be addressed by DMG in the context of a response to this TDN. We will point out that the items mentioned in AFO's letter are being addressed through NOV's issued during the inspection and subsequent permit revisions. 4. Paragraph 2, page 4 of AFO's letter refers to DMG's assertion that reclaiming the refuse piles with four feet of cover at this time would require potentially unnecessary disturbance of a nearby borrow area. AFO goes on to say that DMG is inferring a new concept not included in the Roadside permit. The disturbance DMG referred to was the potentially unnecessary excavation of enough material from the approved borrow area to place four feet of cover on the piles. For example, approximately 89,000 cubic yards of earth are required for one foot of cover on the piles while 371,000 cubic yards are required for four feet of cover. The point of our dsicussion was that placement of four feet of cover on the pile will entail a larger disturbance at the borrow area than placement of a lesser amount of cover.