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<br />-5- <br /> <br />c. Measures which have been employed to protect the stockpiled <br />materials from wind and water erosion and contamination as reouired <br />by Rule 4.06.3 should be addressed as well as any sediment control <br />measures. Any protective berms or diversions should be delineated <br />on the mine surface drainage map and dimensions should be provided. <br />d. Contradictory statements regarding soil replacement depth should be <br />eliminated from the application. Apparently, the approved plan <br />entails replacement of an average depth of 4" of the stockpiled <br />soil material on top of the regraded spoils. Page 2.04.9(13) of <br />the application contains a commitment to test the replaced soil <br />plus the top 12 to 18 inches of graded overburden to insure its <br />suitability as plant growth material. Page 2.05.4(2) indicates <br />that regrading will be conducted as necessary to insure that <br />suitable plant growth material ends up on the surface of the <br />regraded slopes. <br />Assuming that the above paragraph accurately describes the approved <br />plan, the following statements should be eliminated or clarified: <br />"Total estimated amount of soil reouired for reclamation of <br />permit area is 6,736 yards" (2.04.9(10)1. <br />ii. "Topsoil shall be placed to a finished depth of 6 inches over <br />all oraded and backfilled areas" (2.05.4(6)). <br />iii. "It is not expected to be necessary to obtain outside topsoil <br />to achieve a topsoil cover of 6 inches" (2.05.4(7)). <br />iv. "Total estimated amount of soil re auired for reclamation of <br />the permit area is 6,737 yards" 12.05.4(7)). <br />7. A review of the permit application, findings of compliance and onsite <br />inspections has raised a number of concerns with regard to storaoe and <br />disposal of coal mine waste. <br />The findings document and various sections of the permit application <br />indicate that waste material generated from rock fall within the mine <br />would be temporarily stockpiled on the surface fora maximum period of 6 <br />ngnths and periodically backstowed within abandoned workings. Both <br />documents imply that a maximum of 10 to 26 tons of material would be <br />temporarily stockpiled on the surface at any one time. This would <br />correspond to less than 30 yd3 of material. <br />Other statements in the text of the application imply that an unspecified <br />Quantity of waste rock would remain in surface storaoe for use as final <br />reclamation fill material. In addition, on Paoe 2.05.4(5) it is stated <br />that "it is anticipated that unsuitable product materials to be extracted <br />from the mine area in the future may effectively be utilized as backfill <br />materials in the areas of reclamation." However, approved postminino <br />reclamation contours evidently do not reflect any surface disposal of <br />coal mine waste, and as ore vious stated, the findings document indicates <br />that all coal mine waste material would be backstowed, with no surface <br />disposal approved. <br />