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i <br />C-1994-082 / TR-38 <br />MLT Comments <br />19-Dec-2008 <br />Page 2 of 2 <br />will be followed once NWCC's final report is available. Will the final report be <br />submitted as a continuation of TR-38? Does SCCplan to submit a subsequent <br />Technical Revision application requesting Division approval of the <br />recommendations and remediation, along with a proposed construction <br />schedule? It would be prudent to develop a mutual understanding of the <br />process to be followed, even though the specific remediation measures and <br />schedule of construction are unknown at this point. <br />3. DRMS Request: Please provide explanation for inclusion in the permit, <br />addressing how the data from the four cased holes will be used in the analysis of <br />the failure mechanism and design of proposed remediation efforts, along with a <br />description of any additional field investigation methods that are likely to occur, <br />in light of the apparent data limitations noted by the Division. <br />SCC Response: NWCC completed a Supplemental Subsurface Investigation at <br />the site on November 20, 2008. The supplemental investigation consisted of the <br />drilling of two additional test holes to the east of the slide area and upstream of <br />the failure area. The test holes were advanced to depths of 45 and 50 feet beneath <br />the existing ground surface and into the underlying bedrock materials. Both test <br />holes were cased with slotted and solid 2-inch diameter PVC pipe. In addition, <br />PVC casing was installed in new test holes drilled adjacent to the previously <br />drilled test holes 4, 5 and 7 so that the groundwater and soil movement can be <br />monitored. The test holes were advanced into the underlying bedrock materials <br />and cased full length with 2-inch diameter solid and slotted PVC pipe. <br />MLT Comment: The addition of five new monitoring locations, two of which <br />are outside (upstream) of the failure area, together with the description of <br />monitoring frequencies provided in SCC's response to Item 1, successfully <br />addresses the Division's request. The Division has no further comments. <br />This concludes my review of Seneca Coal Company's response to the Division's <br />Adequacy Review for TR-38. Please let me know if you have any additional questions. <br />xc: Sandy Brown --ie-