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La <br /> narrative provided how this volume was derived, and where the <br /> borrow area is located. Please provide a more detailed discussion <br /> of the reclamation to be performed in the South Portal area, source <br /> of the backfill material, and documentation of the quantity needed. <br /> 4 . On page 189, the application indicates that coal processing <br /> waste may be utilized for backfill in the portal decline at the <br /> North Portal , and states that if coal processing waste is used, a <br /> reclamation plan including a discussion of the projected effects of <br /> disposal would be submitted prior to backfilling. This is <br /> essentially in conformance with Stipulation No. 1 , which specifies <br /> that the disposal plan would need to be submitted six months prior <br /> to backfilling. <br /> The Division's policy with respect to stipulating that final <br /> reclamation plan components be submitted at some future date has <br /> evolved since the time that the stipulation was originally issued. <br /> To ensure that reclamation in compliance with applicable rules and <br /> regulations is feasible, that potential hydrologic impacts of <br /> mining and reclamation are properly evaluated, and that reclamation <br /> costs are accurately assessed, it is required that the permit <br /> application package contain a detailed and comprehensive <br /> reclamation plan. We are therefore requesting that a specific <br /> backfilling and grading plan for the North Portal Decline be <br /> submitted with the midterm response revision. <br /> If coal processing waste is to be used in the backfilling of the <br /> decline, the disposal will need to be designed, constructed, <br /> inspected and maintained in accordance with applicable requirements <br /> of Rule 4 . 10 , including replacement of an appropriate surface cover <br /> thickness of the best available non-toxic, non-combustible <br /> material. The plan will also need to demonstrate that coal <br /> processing waste material will not be placed in contact with the <br /> recovered water table level (e.g. the level of the Colorado River) . <br /> The source and volume of coal processing waste and other backfill <br /> material , including non-toxic fill to be placed on the surface, and <br /> below the water table will need to be specified. <br /> 5. Page 192b of the application contains a commitment to submit a <br /> rill and gully inspection report annually by June 1 each year. The <br /> commitment was incorporated into the permit in January, 1995. The <br /> report for this year has not yet been submitted. <br /> 6. Quarterly Refuse Pile site inspection reports have been filed <br /> with the Division as required, and the reports address the specific <br /> requirements of Rule 4 . 10. 2 (a)-(d) . However, the report form <br /> lacks a certification statement specifying that the fill has been <br /> constructed as specified in the design approved by the Division, as <br /> required by Rule 4 .09 . 1( 11 ) (b) . The inspection report form should <br /> be modified to incorporate the required statement. <br />