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direct knowledge of how the road was constructed, please advise the Division of this. The <br /> Division is in the process of rulemaking concerning this issue. <br /> 8. The Division believes that certain corridors within the loadout facility are actually roads and <br /> should be permitted accordingly. It is the Division's understanding that the ramp designation <br /> was approved because road certifications were not possible, due to not having direct <br /> knowledge of how the roads were constructed. <br /> However, Rule 4.03.1(1)(d) states that haul road certifications are needed only when the haul <br /> road is not within the disturbed area, as defined by Rule 4.05.2(4). In other words, if the <br /> haul road was constructed in an area that was disturbed for reasons other than having a haul <br /> road, then that haul road is within the disturbed area. This would seem to apply to the haul <br /> roads within the facility area, so haul road certifications would not be necessary. This would <br /> also be the case for access roads within the disturbed area. <br /> Please submit designs, per 4.03.1, 4.03.2 and 4.03.3, for haul roads, access roads and light- <br /> use roads within the facility area. Please refer to Rule 1.04(111) for the definitions of each <br /> type of road. The Division believes that the road leading from the tie-across haul road to the <br /> truck dump hopper and back to the tie-across haul road should be considered a haul road. <br /> The Division also believes that the road leading from the tie-across haul road to the office <br /> should be considered an access road. Depending on use, the extension of this road past the <br /> office area and down to the loadout facility may also be considered an access road. Also, <br /> depending on use, the road leading from east of the truck dump hopper down to the crusher <br /> building may be considered an access road. Finally, the road encircling the stacker tube area <br /> and the road leading to well HGDAL2 should be considered in this analysis. <br /> In a related matter, pursuant to Rules 4.03.1(4) and 4.03.2(4), haul roads and access roads <br /> may need to have designed ditches capable of passing the runoff from a 10-year, 24-hour <br /> event, plus freeboard of .3 feet. Please submit haul road and access road ditch designs that <br /> can be applied to all of the road ditches at the facilities. Of particular importance is the road <br /> ditch on the west side of the east entrance road. This ditch carries runoff from the coal <br /> stockpile area into the loadout truck loop pond 1. <br /> Rule 4.04 <br /> 9. In Tab 13, on page 3, it is stated that all on-site coal storage ended in 1986 and that, <br /> therefore, water monitoring from 1987 through 1992 was not influenced by coal stockpile <br /> leachate. However, a small amount of coal still resides in the coal stacker tube area. Please <br /> revise this page to show that at least some coal is still on site, even through Peabody may <br /> still contend that the remaining coal did not contribute to any coal leachate problem. <br /> 10. Railroad loops and spurs are covered under Rule 4.04, Support Facilities. Rule 4.04(1)(b) <br /> requires that the runoff from a support facility must meet applicable State and Federal <br /> limitations for suspended solids. Rule 4.05.2 requires that these limitations be achieved <br /> through the use of a sedimentation pond or, per Rule 4.05.2(3), a small area exemption. <br /> Because a sedimentation pond would be impractical in this case, please submit SAE <br /> demonstrations for those segments of the railroad spur and loop that do not report runoff to a <br /> -4- <br />