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• <br /> <br /> <br />significantly in excess of 1.5, the required factor in Section <br />9.10 of the regulations. <br />2. The pads will be located approximately 100 feet above the <br />local groundwater table, and will therefore not be subject to <br />saturation by groundwater flow, infiltration, or surface flow. <br />3. The material from which the pads are formed is non-acid <br />generating, and is not considered likely to produce any <br />observable degradation of groundwater or surface water <br />resources. <br />4. The mine waste material that will be used for the pads is non- <br />combustible; the Willcox coal seam is the first seam encoun- <br />tered in the tunnels. Accordingly, combustion of the waste <br />rock material will not occur at this site. <br />5. To enhance the hydraulic performance of the pads, it is <br />proposed to end dump the material which will form them, in <br />order to take advantage of the segregation of the materials <br />that occurs during end dumping. This will result in a higher <br />permeability toe drain of large rock boulders. The design <br />slope for the pile is 2h:ly, which will be achieved by push- <br />dozing material down the slope after end-dumping. The rock <br />material will be compacted in lifts of two feet or less. The <br />pads will be inspected quarterly by a registered professional <br />engineer. <br />6. Following the completion of the pad slopes, they will be <br />covered with 16 inches of topsoil (the same depth that is <br />predicted for all reclaimed areas on the project, due to <br />limitations of topsoil supply). This is less than the <br />Regulation preferred 9 feet, but is more than adequate, due to <br />the non-acid generating nature of the waste rock. NCIG will <br />commit to establishing field trials to demonstrate that 16 <br />NCIG - Coal Ridge #1 <br />4-51 <br />ABC/1145/910509 <br />%n' / <br />