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COMMENT: Inspection requirements by a professional engineer will <br />be met and certified reports will be filed. <br />Rule 4.09.1(12)Coal processing wastes shall not be disposed of in head- <br />of-hollow or valley fills, and may only be disposed of in other excess <br />spoil fills, if such waste is: (a)...; (b)...; and (c)... <br />COMMENT: No coal processing wastes are involved, and therefore, this <br />section is not applicable. <br />Rule 4.09.1(13) <br />If the disposal area contains springs, natural or <br />manaade watercourses, or vet-weather seeps, an undetdrain <br />system consisting of durable rock shall be constructed from <br />the vet areas in a manner that prevents infiltration of the <br />water into the spoil material. The underdrain system <br />shall be protected by an adequate filter and shall be <br />designed and constructed using standard geotechnical <br />engineering methods. <br />COMMENT: Our additional field investigations of August 2-3, 1984 <br />further confirm that a subsurface source of water does exist in the <br />area of the mine bench. An underdrain system, in compliance with this <br />• regulation, will be designed and discussed in Appendix 1-B. <br />Rule 4.09.1(14) <br />The foundation and abutments of the fill shall <br />be stable under all conditions of construction and <br />operation. Sufficient foundation investigation and <br />laboratory testing of foundation materials shall be performed <br />in order to determine the design requirements for stability <br />of the foundation. Analyses of foundation conditions shall <br />include the effect of underground mine workings, if any, <br />upon the stability of the structure. <br />COMMENT: The foundation and abutments of the fill will be stable under <br />all conditions of construction and operation. Investigations and <br />laboratory testing on foundation material have been performed to demon- <br />strate stability in this phase of construction. Since the E seam <br />outcrops just east of the mine bench, there are no mining projections <br />by Blue Ribbon. U. S. Steel Corporation, however, does mine lower <br />coal seams in this area. Potential effects of that undermining have <br />• been taken into account in the final designs mentioned in Appendix 1-B. <br />-9- <br />