2009-08-06_REVISION - C1982056 (2)

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C1982-056: TR67 Adequacy 2 August 6, 2009 3. Based on the table on page 10 of Exhibit 26C, TCC will salvage approximately 723,463 cubic yards of spoil from the CRDA expansion footprint, but proposes to replace only 567,824 cubic yards over the surface of the Refuse Pile. How does TCC propose to handle the 155,639 cubic yards of excess salvaged spoil? Please provide a mass balance of the salvaged and replaced topsoil, and the salvaged and replaced spoil for the CRDA. If placement on the existing RDA is part of this balance, please provide that explanation so the Division has an understanding of where this material will be placed and so TCC does not end up with an excess salvaged spoil pile at the end of the life of the CRDA. 4. Since the construction of the pile is presented in 2 phases, please also provide a mass balance showing the topsoil and cover (spoil) volumes if the construction of the CRDA were to be stopped after the phase I development. 5. TCC provided cross sections of the proposed CRDA: A-A and B-B. Cross-section A-A extends from the western extent of the proposed pile through to the eastern extent of the proposed CRDA. Cross- section B-B shows a segment initiating from approximately 50 feet north of the toe of the proposed CRDA expansion and extending roughly 2/3 of the way through the pile. TCC provided no cross- section depicting the southern end of the CRDA expansion and how the southern extent of the CRDA expansion ties in with the topography on the southern extent. 6. The CRDA cross sections map shows the proposed refuse elevation and grading at Phase I, but this map does not show the ditches associated with phase I construction. The ditches should be depicted on the cross section map too. The CRDA cross sections map also depicts Phase 2 contours, which are approximately 150 feet lower than the final grade. The text indicates there are two phases; Phase 1 and final, yet the cross-section map shows Phase 1, Phase 2 and final contours. Please explain the phases of pile construction. 7. Exhibit 26C indicates that a minimum of 2 piezometer wells be installed in the CRDA expansion to monitor water within the pile. The maps do not show where these piezometers will be placed nor is there any discussion regarding how the piezometers will be constructed or frequency of monitoring. A description of number of piezometers, location of piezometers, construction methods, construction timing, monitoring methods and frequency needs to be included in the discussion. 8. TCC provided a reclamation cost estimate for partial reclamation of the CRDA expansion in Appendix A: Reclamation Cost Estimate. TCC's Exhibit 26C states that approximately 140 acres will be redisturbed with the expansion of the CRDA. However, the reclamation cost estimate only provides values for 50 acres of disturbance. The Division cannot approve disturbances that do not have reclamation bond associated with them. Either TCC needs to include reclamation costs for the entire disturbance, Rule 3.0.1(3) and Rule 3.02.1(5)(a), or TCC may elect to apply a cumulative bond schedule to the construction of the CRDA expansion in accordance with Rules 3.02.1(5)(b) and 3.02.1(6). If TCC chooses to apply a cumulative bond schedule to construction of the CRDA expansion, no construction activity or disturbance may proceed until the Division has received and approved bond appropriate to the proposed activity. The limits of bonded disturbance will need to be clearly marked on the ground.