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y v • • -6- Currently, the amount of mine waste far exceeds that quantity reference document, and the material has been considerably longer than 6 months. Division in October, 1989, a volume Attachment 1). stored in the approved storage site in the application and the findings stored on the surface for Based on measurements taken by the of 11,766 yd3 was estimated (See There would appear to be two options available for handling existing and anticipated future coal mine waste material. One option would be for all mine waste to be backstowed as discussed in the application and findings document. Application references to surface disposal of coal mine waste would need to be deleted and a compliance schedule would need to be set up to reduce the volume of surface stored material to less than 30 yd3 within a reasonable period of time. A detailed discussion of the backstowing plan demonstrating compliance with Rule 2.05.3(a) and (b) would need to be submitted if this option is selected. A second option would be to store and dispose of existing and future coal mine waste material on the surface. If this option is chosen, design plans addressing storage and disposal of coal mine waste as required by Rule 2.05.3(8) and 4.10 will need to be submitted. Also, if the proposed disposal site is within the current disturbed area, the final reclamation contour map and cross sections will need to be revised as appropriate. The reclamation cost estimate will need to be revised to reflect the costs of moving, grading, compacting and covering the anticipated volume of waste. 8. Sections of the permit application which address subsidence projections, observed subsidence features, and the current subsidence monitoring plan need to be updated to reflect the information gathered since permit issuance. Of particular significance is the cracking reported in the October, 1989 Quarterly subsidence monitorino report, which was observed above the 3rd East Panel. Recently installed subsidence monuments installed above the 2nd and 3rd East Panels should be depicted on the appropriate permit area map. 9. A review of the quarterly around water data collected since permit renewal in 1987 indicates that analyses for two reouired parameters, bicarbonate and sodium; have not been submitted. The apparent omission should be addressed and the two parameters should be added to the quarterly monitoring list immediately. Manganese analyses have been routinely performed, but are not reouired, based on the parameter list in Table 1 of the July 9, 1987 findings document. Analysis of manganese can be deleted from the regular quarterly around water monitoring list, if desi red. 4235E