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INTEROFFICE MEMORANDUM <br />TO: KENT GORHAM <br />FROM: JANET BINNS <br />SUBJECT: FOIDEL EK MI 82-056, 33 <br />DATE: 12/12/2008 <br />CC: DAN HERNANDEZ <br />TCC has submitted a minor revision to construct a temporary Clay staging area on a reclaimed Excess Spoil Pile <br />(OSP#1). TCC proposes to strip clay (subsoil) material from the west of the Refuse Disposal Area (RDA) and <br />transport it by scrapers to a reclaimed and Phase III bond released area to the south of the RDA. The OSP#1 was a part <br />of the Eckman Park permit. The Eckman Park permit has received final bond released years ago. The OSP#1 was <br />approved to remain as a permanent excess spoil pile. TCC proposes to disturb approximately 5 acres on the top of the <br />OSP#1 pile. Sediment control is proposed to be controlled by the existing ditches and benches on the OSP#1 pile. <br />TCC will direct any runoff from the benches north across a permanent post-mining road to Ditch RDA-le. Ditch <br />RDA-1e reports to Pond D. <br />The OSP#1 is well vegetated and has been stable for many years. TCC will salvage topsoil prior to constructing the <br />temporary Clay staging area. A portion of the permanent road will be used as a temporary Light-use road. <br />I conducted an inspection on 12/9/2008 and TCC had already begun construction of this Clay staging area. Sediment <br />control measures were already in place. NOV CV2008-006 was issued for failure to receive final approval of a <br />revision prior to implementing. While on site the operator located portions of the Eckman Park permit with <br />descriptions of the OSP#1 pile and the benches for incorporation into the Foidel Creek permit. The descriptions in the <br />Eckman Park permit lacked detail and only described the structures generically. <br />I have reviewed TCC's MR233 application with the following comments: <br />TCC needs to demonstrate that the benches and ditches on the OSP# 1 are adequate to pass a 10-year <br />precipitation event (10-year, 24-hour [Rule 4.05.3(3)] <br />TCC needs to demonstrate that the "ditches" (benches) meet Rule 4.05.3(7). <br />The road from the south end of the RDS to the Clay staging area can be designated as a light Use road <br />(Rule 4.03.3). TCC needs to assure this light use road complies with the requirements of Rule 4.03.3(3). <br />Any culvert s for the light use road will need to complywith Rule 4.03.3(4)(b). [10-year, 24-hour event] <br />Please review TCC's MR233 for hydrology concerns and provide me any additional comments you deem necessary for <br />the operator to provide. I gave TCC until 12/19 to receive approval for MR233. <br />Thank you for your help.