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Mr. Jim Stover, P.E. <br />July 16, 2008 <br />Page 5 <br />need for sequential interim ditching (at interface of fill bench and native slope) <br />that would be warranted as pile construction progresses up the slope was not <br />addressed. <br />Please amend the coal mine waste disposal sections of the application to <br />address measures that will be taken to divert runoff from above the pile and <br />direct flow safely from the working bench to stabilized channels off the fill <br />during construction phases. Include interim ditch specifications and <br />sequenceltiming for construction of interim and final ditches. <br />Rule 2 05 3(5) and 2.05.4(2)(d) Topsoil and Subsoil Removal. Storage, and <br />Redistribution <br />36. The Division noted that sections of the reclamation plan addressing topsoil and <br />subsoil (refuse cover soil) removal, storage, and replacement (Permit Sections 3.2 <br />and 3.3) were not amended to address TR-16 proposed disturbances, and <br />requested that the sections be amended as appropriate. <br />Sections 3.2 and 3.3 of the application were revised to incorporate the TR-16 <br />proposed disturbances. We believe additional detail regarding soil replacement is <br />warranted. <br />a) A two foot average uniform replacement topsoil thickness is specified for the <br />proposed disturbances within the AVF boundary, but replacement thickness for <br />other proposed disturbance areas is not specified. Average uniform <br />replacement thickness for the proposed coal mine waste disposal area, <br />material storage area, and construction material stockpile also need to be <br />specified within the text. <br />b) There is reference on page 3-9 to use of soil salvaged from sediment pond <br />cleanings, for reclamation of the access road alignment and approximately one <br />acre of the mine bench. This language appears to be outdated, since coaly <br />sediment likely to be generated from active use areas will be unsuitable for plant <br />growth medium. Please amend the subject narrative to clarify whether the <br />material that will be used to top-dress portions of Haul Road 1 and the mine <br />bench area will be obtained from the topsoil stockpile or the construction <br />material stockpile. <br />37. through 43. Items Resolved. <br />Rule 2.05.02)(c) Plan for Backfilling_and Grading <br />43(a). Item Resolved. <br />44. The Division requested the operator to amend the Figure 3.1-1 topography, <br />permanent channel configurations, and revegetation community type delineations,