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<br />The sampling shall occur twice annually and a report of findings shall be submitted to the <br />DMG with the annual report.' <br />In regard to Harry Posey's memorandum of December 17, 1999, his item number 2 <br />requests that the operator commit to spraying the freshly deposited CKD with water to <br />promote crystallization and inhibit leaching. Southdown has been voluntarily doing this <br />for about two years (along with mixing the CKD with water in a pug mill at the cement <br />plant prior to transport to the disposal area) and will hereby commit to these practices in <br />this Technical Revision: The pug mill mixing occurs all year while the spraying at the <br />disposal area occurs during times of year when the temperature is generally above <br />freezing. <br />Item No. 3 -Installation of Interim Compacted Shale Cover <br />The applicant proposes to utilize a clayey shale material for the CKD cap material. The <br />material exists as overburden on an adjacent mining site. The material will be <br />excavated, loaded into mining haul trucks, and hauled to agrizzly-hopper for unloading. <br />The grizzly-hopper will transfer the shale onto an overland conveyor. The material will <br />be conveyed and temporarily stockpiled near the reclamation site. The material will be <br />loaded into haul trucks for final transportation. The material dumped by the haul trucks <br />will be spread with a bulldozer in loose lifts not to exceed one-foot thick, prior to <br />compaction. Total thickness of the cap shall not be less than qpg hick after <br />compaction. Moisture levels will be adjusted by water additions during the conveying <br />process and after placement with a water truck, as necessary. The material will be <br />compacted in-place by wheel-rolling with the large mining equipment. The applicant will <br />utilize additional equipment if adequate compaction cannot be achieved with on-site <br />equipment. The compacted cap will be a minimum of one-foot thick, with surface <br />grading between 1 and 4%. <br />The material properties, reasonable moisture control and compactive effort outlined <br />above will achieve an adequate level of imperviousness to minimize precipitation from <br />leaching through the CKD into the groundwater. After the final cover is placed topsoil <br />will be applied and the area will be planted as currently permitted and bonded. <br />Please let me or John Lohr know if you have any questions <br />Si rely, <br />~)!~.~- <br />Paul Banks <br />PB/kj <br />CC: John Lohr <br />Attachments <br />