REV92771

• Permit No: C1982057
• IBM Index Class Name: Revision
• Doc Date: 3/23/2004
• Doc Name: Adequacy Review Concerns
• From: DMG
• To: Seneca Coal Company
• Type & Sequence: TR48
• Media Type: D
• Archive: No

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TR-48 PRELIMINARY ADEQUACY REVIEW
The Insertion Instructions Page should be updated to reference replacement of page
7, in Tab 13, Volume 7.
2. Insertion Instructions Page erroneously references new Exhibit 13-9b "Pond 016A
As-Built", under Tab 13, Volume 9. The referenced exhibit already exists ("Pond
016 Design Revision"). The new map should thus probably be designated 13-9c.
The actual exhibit map submitted is for some reason designated Exhibit 16-9C,
which would appear to be an error. Please amend the Exhibit designation and
insertion instruction reference as appropriate.
Table 13-5...Design Statistics for Culverts...
There are 3 culverts not indicated on the original, previously approved design map.
One of these culverts (K5) appears from the map Exhibit 13-23.1A (and comparison
with approved Exhibit 13-23.1) to be associated with a segment of the haulage
route within the immediate pit disturbance vicinity, and thus not actually on a
designated haul road subject to specific design standards. Please verify that this is
the case. Inclusion of the pit boundary on Exhibit 13-23.1A, as shown on Exhibit
13-23.1, would be helpful. On the new Road K Construction Summary page text,
applicant states that this culvert is "a temporary 36-inch culvert that directs
temporary flows from the disturbed area to Pond 017. This culvert will be removed
once drainage concerns are decided and approved by the Division and SCC". Please
clarity on both the exhibit and the construction summary page that the culvert is
located on a travel route within the immediate mine pit area. Also, the construction
summary page is designated 13-51.2, which would appear to be an error, since
Appendix 13-51 pertains to Pond Ot6A "As Built". The erroneous page designation
will need to be corrected.
Pond 006 Phase V As Built Documentation
4. Performance of the as-built structure has been demonstrated to be in compliance
with the rules applicable to settleable solids. However, there is an inconsistency in
the in the design documentation. The "Structure Summary" on page 4 of the
SEDCAD run for the As-Built design indicates a peak settleable concentration of
0.01 ml/I, which conflicts with the summary page listing of 0.02 ml/I. Also,
information has not been presented to demonstrate compliance with rules
associated with flow elevations through the emergency spillway. Please amend the
summary page to correspond with the SEDCAD run. Also, please provide a 25-year,
24-hour SEDCAD run for Pond 6 Phase V to demonstrate compliance with
emergency spillway flow elevation.
Pond O16A As-Built Documentation
There are a couple typographical errors on page 13-51-2, Certification Statement,
which need to be corrected. "8CC" should be "SCC". Also, in same sentence,
"4.OS.6" and "4.OS.9" should be "4.05.6" and "4.05.9", respectively.
6. The SEDCAD runs and hydrology details are acceptable for the Pond 016A As-Built.
Final "As-Built" certification for the entire pond (rather than just the embankment