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Deserado TR 39 Preliminary Adequacy Review <br />1. The revised text page submitted with the application was <br />numbered IV-23. This appears to be an error, as the text <br />corresponds to current Page IV-24, and the page should be amended. <br />2. The revised text contains the following statement: <br />WFU will maintain drainage and sediment <br />control during the refuse pile construction <br />and prior to final reclamation on an as needed <br />basis. Final construction of erosion control <br />ditches around the refuse areas will be <br />completed during the final reclamation process <br />to meet design specifications. <br />It is requested that a more detailed explanation be provided <br />regarding which aspects of the ditch construction pursuant to the <br />approved design will not be completed until final reclamation. It <br />is reasonable that revegetation of sediment pond collection ditches <br />currently subject to deposition of coaly sediment and frequent <br />maintenance not be completed until final revegetation of the refuse <br />pile is undertaken. These ditch segments should be identified in <br />the permit, and interim stabilization measures should be described. <br />It is also recognized that certain permanent ditch segments may not <br />be completed in their final location or with final riprap designs <br />until the refuse pile reaches design elevation. These ditch <br />segments should be identified in the permit, and interim drainage <br />control and stabilization measures should be described. <br />In general, any permanent ditch segments which will not be <br />constructed until :;ome later stage of refuse pile construction, and <br />any elements of approved final ditch design which will not be <br />implemented at the time the ditch segment is constructed, will need <br />to be identified a:nd justified in the permit application. <br />3. The uniform four inch rounded river rock that has been used as <br />riprap in various locations associated with RP-2/3, RP-4, and RP-5 <br />perimeter ditches, and the RP-5 Sediment Pond inlet is <br />inappropriate, and not acceptable for long term channel <br />stabilization. Note that the SEDCAD channel designs included in <br />the approved permit and the TR application are based on graded <br />riprap with DzO of 6", D,,, of 7.5", and D,o of 2". The river rock <br />will need to be replaced with graded riprap of durable, angular <br />stone, to be specified in the amended application. The riprap <br />3 <br />