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2.05.3(8) Coal Mine Waste And Non-Coal Processine Waste <br />9. Map 76 presents generalized designs, layout, proposed development schedule, and projected <br />capacities for existing and proposed refuse disposal sub-areas at Deserado. The projected <br />refuse capacity of 2034 acre feet (3, 381,520 cubic yards) for Sub-area 2-3&4 combined <br />appears to be in error. Based on a 1.2 ton/cu.yd. refuse density derived from final RP-1 <br />refuse tonnage and volume information, the projected capacity for RP 2-3/4 would be 3,937, <br />824 tons. However, based on certified quarterly reports, 4,739,345 tons of refuse had been <br />placed in the combined sub-area as of October 2001, significantly exceeding the projected <br />capacity. <br />Please address this appazent discrepancy, and amend the Map 76 capacity <br />projection/timetable for Sub-azea 2-3&4, as well as other listed sub-areas, as appropriate. <br />10. Use of refuse sub-azea SB is projected to be initiated in 2005. It is assumed that soil <br />stripping operations would need to be initiated in 2003 or 2004, to coordinate with <br />reclamation of Sub-area 2/3/4. Detailed construction and final reclamation designs for <br />Refuse Pile SB, including drainage and sediment control designs will need to be submitted <br />and approved prior to initiation of disturbance. Please address the anticipated date for <br />submittal of RP-SB detailed designs. <br />11. There is an erroneous statement in pazagraph 3 on p. IV-34, indicating that "fills in disposal <br />area are Sh:lv..." The reference should be amended, since approved design for active <br />refuse areas allows for maximum 4h:1 vertical slopes. <br />12. Tent on page IV-23 states that the "reclamation of sub-areas 1,2,3 and 4 is shown on Map <br />77. Map 83 shows final cross sections of these azeas." This statement appeazs to be <br />erroneous and incomplete, and needs to be updated, along with certain associated maps and <br />cross sections. Map 77 appeazs to depict approved reclamation designs for sub-azea RP-1, <br />only, as the design for RP 2-3/4 is outdated and references Map 150 for drainage and <br />postmine contours. RP-1 contours shown on Map 77 appeaz to correspond to the as built <br />pile topography, but differs appreciably from the RP-1 topography depicted on Map 81 <br />(Sites 1,2,3 & 4.Reclamation Map). The sub-azea 2-3/4 cross section on Map 83 appears to <br />be outdated and erroneous, as it was taken from Map 77, which does not show approved <br />contours. RP-SA contours and cross sections are shown on Map 77A, which is not <br />referenced in the text. In summary, Maps 77, 81, and 83 appear to be the source of <br />considerable confusion, and they need to be properly amended to reflect approved <br />designs. Text reference should be appropriately updated to include reference to Map <br />150 for RP-2-3/4 final design and Map 77A for RP-SA £mal design. <br />13. Permit application narrative does not address how refuse area design and construction will <br />achieve compliance with Rule 4.09.2(5), which specifies that "drainage shall not be directed <br />over the outslope of the fill". Refuse Area 2-3/4 and Refuse Area-SA designs depict <br />Deserado Mine Apri130, 2002 <br />10 <br />