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<br /> <br />-3- <br />The applicant proposes a monitoring program limited to monitoring of two <br />ground water wells and the installation and monitoring of several piezometers <br />within the structure. The Division finds this monitoring proposal to be <br />seriously deficient. In light of the downslope existing landslide and the <br />general concerns for surficial and possible deeper stability problems, the <br />Division believes it will be necessary to require a significantly more <br />comprehensive stability monitoring program. Until the above addressed <br />technical concerns are resolved, it will be difficult to discuss specific <br />monitoring program components. However, the Division believes that, at a <br />minimum, slope movement survey monuments and/or tilt meter installations will <br />be necessary. <br />The permit revision application presents a proposed reclamation plan for the <br />upper waste pile and its associated haul road. The plan calls for reclamation <br />when construction is complete. The Division believes that the disturbance and <br />reclamation plans should be capable of phasing, which might allow topsoil to <br />be stripped and immediately placed upon earlier completed portions of the pile. <br />The application proposed to limit final cover material placement to 18" of <br />material. As the applicant states, the regulations within Rule 4.10 require <br />48" of cover, unless revegetation success can be demonstrated using a lesser <br />thickness. The applicant proposes to complete such an analysis and <br />demonstration. During this demonstration, however, the Division believes it <br />appropriate to salvage at least 48" of the average 65" of soil and subsoils <br />located in the areas to be disturbed, in case these materials are eventually <br />required to cover the structure. <br />***[BOB -- I BELIEVE YOU SHOULD ELABORATE UPON THE ABOVE COVER DISCUSSION.]*** <br />The permit revision application presents a bonding calculation for the <br />proposed disturbances. Depending upon the result of the final resolution of <br />some of the above-addressed concerns, the Division may require amendment of <br />the bonding proposed in order to include funds to support monitoring <br />activities in the event of forfeiture. <br />/md <br />Doc. 5831E <br />