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materials having visually differing physical characteristics, and provide test <br />results for these additional samples, consistent with the original testing <br />performed by Buckhorn Geotech. Please provide an updated stability <br />analysis, as appropriate, based on the additional test results. <br />35. Recommendation No. 4 of the Appendix "R" Stability Evaluation states that the <br />gob pile should be designed and graded to shed surface water and precipitation off <br />all portions of the pile both during and after gob placement. Applicable <br />regulations specify diversion of surface drainage from above the waste bank and <br />from the crest and face of the waste disposal area (4.10.3(2)), and further specify <br />that drainage shall not be directed over the outslope of the fill (4.09.2(5)). Based <br />on design grades and ditch locations depicted on Figure 2.2-3 topography and <br />cross sections, it appears that the final pile configuration would comply with the <br />referenced rules and stability evaluation recommendation. However, it is not <br />clear from design figures or narrative how compliance with the drainage <br />requirements will be maintained during interim stages of waste pile construction <br />(to divert runoff from above the pile and from the pile surface to stabilized <br />drainages off the fill, prevent runoff from being directed over the outslope, and to <br />prevent ponding on the fill). Demonstration of compliance will likely require <br />grade specifications for completed lifts, and may require use of a series of <br />properly sized temporary collection/diversion ditches that would be replaced or <br />extended as waste pile elevation increases. <br />Please amend the coal mine waste disposal sections of the application to <br />address measures that will be taken to ensure compliance with applicable <br />surface drainage requirements during pile construction, in addition to the <br />design information presented for the final configuration. <br />Rule 2 05 3(5) and 2 05 4(2 (d) Topsoil and Subsoil Removal, Storage, and <br />Redistribution <br />36. Sections of the reclamation plan addressing topsoil and subsoil (refuse cover soil) <br />removal, storage, and replacement (Permit Sections 3.2 and 3.3) were not <br />amended to address TR-16 proposed disturbances. <br />Please provide amended permit Sections 3.2 and 3.3 to incorporate TR-16 <br />proposed disturbances. The amended sections will need to address all <br />requirements of Rules 2.05.3(5), 2.05.4(2)(d), and 4.06, as well as Rule <br />4.10.4(5) (regarding quantity and quality of material to be segregated from <br />topsoil during salvage operations and separately stockpiled for non-toxic coal <br />mine waste cover fill). Revised salvage and replacement plans will need to <br />reflect quantity of suitable topsoil material available in the existing stockpile, <br />as well as suitable topsoil available from currently undisturbed soil map <br />units that will be salvaged in association with TR-16 implementation. <br />Similarly, the projected cover fill volume will need to take into account any <br />11