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RN-03 ADEQUACY REVIEW COMMENTS (11/5/99) 5. We will request confirmation from USFWS that, based on revised water depletion projection, the original USFWS biological opinion of no jeopazdy remains valid We will advise you if any additional action is necessary on your part. 7. Footnotes on Table ILC-12 and II.C-13, as well as narrative in Sec. II.C.3.h, at bottom of P. II.C-73 (8199) are still somewhat vague regarding future monitoring requirements for wells in Leases 8424 and 8425. Please include a statement within the text, or on the Tables, indicting that the wells will be .sampled `within one year prior to scheduled longwall extraction in the well location". 9a. New soils information provided for future refuse disposal areas was generally satisfactory. However, We amended Soils Map (Map 82) is somewhat confusing The map legend refers to "Geotechnical Boreholes", but 4 of the 16 sites depicted are the 1999 soil sample sites (Sl, S2, Pl, P2). The map will need to be appropriately amended to cleazly identify 1999 soil sample sites, to prevent future contusion The geotechnica] borehole sites are shown on Map 76, and do not need to be depiMed on Map 82. 9b. Based on the tables in new Appendix IVA, future refuse azeas with the exception of Area 11 are projected to have a deficit of suitable refuse cover material (approximate 6" deficit on average). However, it would appeaz that projected deficits could be abated by supplementation with excess material currently in stockpile Text should be amended to address this situation, affi should include a commitmem to document topsoiUcever soil material balance as future refuse area development and reclamation progresses, to ensure Wet required cover depths are achieved and that deficits do not acc~ve in the future. 17. Original adequacy item included We following wnoern, which was not addressed in the response. "To furWer++>;n»++1~P erosion and sedimentation from We reLttively steep, long outslopes of the refuse piles, it is requested Wet the refine disposal plan be modified to address initiation of final reclamation on slopes which have achieved 5na1 elevation and grade." Please include a commitmem to initiate final reclamation during 20(10, on portions of Area 2/3/4 which will not receive additional refuse material, or demonstrate why initiation of final reclamation on such areas would not be practicable, purnran[ to Rule 4.13. Temporary diversions or older measures to protect reclamation areas from active disposal areas would need to be addressed. 18. Amended text on page IV-23, erroneously cites Rule 4.09.1(12)(b), muter than 4.09.1(11)(b), artd will need to be corrected. 21b. Part I. Response states that Pond RP-5 primary spillway elevation is "5518.6 feet, which is 2.6 fee[ above We required sediment storage volume. This equates to a total pond ppaciry of 12.35 acre feet". Map 80A "Refuse Pond SA As-Built" does not support this statement. Cross section and stage volume curve show primary spillway elevation of 551 S.8 feet, which is 1.65 feet above top of sediment stomge volume. This equates to a total pond ppaciry of less than l0 acre feet. Please address this discrepanry. 21b. Part 2. Resporue correctly states that Map 80A "primary spillway elevation is shown as 5515.8". However, We response states incorrectly that We "elevation of the 3-year sediment load is shown as 5513.15, the elevation 2.5 feet below We primary spillway is 0.15 above We 3-year sediment load elevation." Map 80A stage volume curve shows top of sediment storage volume at 5514.15 feet, which is 1.65 feet below We primary spillway elevation. Please address this discrepanry, as well as We specification in We text irdicating that Pond 5 is to be dewatered to an elevation 2.5 feet below We spillway elevation after inflow. If the stage volume curve and spillway elevations on We map are correct, why would We pond be required to be dewatered to an elevation lower than We maximum sedimem storage level? What is the significance of 2.5 feet?