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that the runoff meets effluent standards, or grassing the <br />peripheral area, in essence fencing in the site with a sediment <br />control design. Please feel free to call me if you have questions. <br />Items 27 through 30: Satisfied. Thank you for your response. <br />Item 31: See response #50. <br />Item 32: Thank you for your response. The Division notes that the <br />revised pages in Appendix B as submitted, commits EFCI to maximum <br />drv density instead of Proctor density testing for the refuse pile. <br />Currently Proctor testing is indicated on page 9 of Exhibit 18. <br />Item 33: Item satisfied. Thank you for your response. <br />Item 34: Regarding the projected angle and actual angle of draw, <br />please refer to EFCI's "SEMI-ANNUAL SUBSIDENCE MONITORING REPORT <br />for May - October 1991, where in the 'Discussion' section, the <br />author indicates the angle of draw is "approximately 27 to 29 <br />degrees." Field measurements together with Division calculations <br />indicate that a more conservative upper ended number for the angle <br />of draw needs to be represented in the permit. Even with a lesser <br />angle than 29, that of 26 degrees, as is currently indicated on Map <br />17, the subsidence effect is off permit boundaries. The problem <br />seems to be one of geometry, in that the subsidence shape is more <br />ovate and your permit boundary more angular in shape, therefore <br />boundary geometries do not match. Measurements by EFCI cannot be <br />discounted when considering subsidence effects. By EFCI's own <br />admission, the angle of draw range is beyond 20-25 degrees, <br />therefore, the Division's position is that the permit boundary <br />incorporate the conservative 29 degrees angle of draw, and be so <br />indicated on a revised Map 17. <br />Item 35: Thank you for your response, however, the scale of 1"= <br />400' for a subsidence map is visually ineffective in illustrating <br />subsidence effects, since only three seam lines are visible on the <br />map. Therefore, please revise the map to a 1" = 200' contour scale <br />as was originally requested in the Midterm review. <br />Item 36: Regarding coal stockpile bonding; it is the Division's <br />policy to bond for 50$ of the stockpile, since the Division is not <br />in the position to market coal and would have to hire someone to <br />market the coal, haul the coal off site, etc. Therefore, please <br />include in your ACZ bond estimate, a 50~ coal stockpile bonding <br />amount. <br />* At this point your response numbering sequence is off by one <br />from the original Mid-term Review sequence. <br />Item 37: Included in response 36 per your April 1993 response <br />letter. <br />item 38: This response is incomplete, due to there was no Map 29 <br />included in the reply. Please forward Map 29 to the Division for <br />