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Michael Boulay May 21-2008 <br />revision proposes the use of only 3 feet of cover material, approval of which <br />would require that physical and chemical analyses in accordance with Rule 4.15 <br />be provided to the Division. It may be that the assumption underlying the <br />narrative is that a minimum of 1 foot of topsoil would be replaced over 3 feet of <br />coverfill soil, to provide the required minimum of 4 feet of non-toxic cover, but this <br />is not clear. <br />Please amend the narrative to clarify that a minimum 4 foot cover of non- <br />toxic material (coverfill and topsoil combined) would be replaced over the <br />waste disposal pile for final reclamation. <br />CAM: Please see clarification on amended page 2-34. After importing the soil <br />boundary lines on to Figure 2.2-2, new quantities were run for the volume of <br />material available for topsoil salvage. Instead of 7760 CY, revised quantity shows <br />11,500 CY are able to be salvaged. The additional topsoil quantity will be used <br />to replace the current topsoil amount in the areas that lie within the boundaries of <br />the AVF as discussed in Adequacy Item #59 (e). Please see the revised topsoil <br />pile design shown on Figure 2.2-2 and 2.2-3 and the text is updated where <br />appropriate. <br />28. DRMS: On amended page 2-35, narrative indicates that the sediment <br />drying area will be removed, and that material stored in the sediment drying area <br />will be placed in the coal mine waste disposal area once it is constructed. We <br />realize that the existing sediment drying area will be eliminated by construction <br />associated with TR- 16 implementation. However, we are concerned that the <br />amended plan does not provide a facility for storage and drying of sediment <br />periodically cleaned from ditches and the sediment pond, prior to placement in <br />the coal mine waste disposal area. Depending on site specific conditions, <br />including physical characteristics and moisture content of the sediment, and <br />phase of waste pile construction, it may or may not be appropriate to place <br />sediment cleanings directly into the coal mine waste disposal area. Given the <br />limited amount of space available within the permitted disturbed areas, inclusion <br />of a designated sediment storage/drying area would appear to be warranted. <br />Please address this concern and amend the application as appropriate. <br />CAM: It is an accepted practice that the sediment periodically cleaned from the <br />sediment pond and ditches will be placed on top of the gob pile and allowed to <br />thoroughly dry and in fact, the Geotechnical Report Conclusions and <br />Recommendations Item #4 addresses placing and allowing the coal mine waste <br />to dry as necessary. In addition, the production of coal mine waste is sporadic <br />and minimal; between 2000 and 2004 coal mine waste was only hauled to the <br />Munger Canyon coal mine waste pile once, so there is not an abundance of <br />waste. The Operator does not believe a designated sediment storage/drying <br />area is warranted. <br />12