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C1982-056: TR67 Adequacy <br />August 6, 2009 <br />The Division has conducted a reclamation cost estimate (RCE) using values for the entire proposed <br />CRDA expansion. The Division had estimated the cost to reclaim the proposed activities for the entire <br />140 acre CRDA expansion is $1,014,846.00. The Division's RCE is included with this letter. <br />9. Permanent Ditches RDA-4 and RDA-3 are shown as constructed into the existing Refuse Disposal Area <br />(RDA). Permanent drainages must conform with Rule 4.10.3(2), Rule 4.09.2(7). The permanent ditches <br />cannot be constructed on top of refuse material. TCC currently has an existing permanent ditch <br />downslope from proposed RDA-3 and RDA-4. TCC needs to direct flow from the refuse pile to RDA- <br />lc and RDA-lb and assure that these ditches continue to be appropriately sized for the additional <br />drainage area. <br />10. Please submit SEDCAD runs that use the NRCS Type II storm that is applicable to the mine location. <br />11. The underdrain designs included in Exhibit 26C and discussions in the revised text discusses wrapping <br />the underdrain with geo-fabric. During a discussion with the operator (Jerry Nettleton) during an onsite <br />inspection on July 15, 2009, TCC indicated that the underdrain would have layers of finer aggregate <br />instead of geo-fabric. If this is a change to the underdrain design, please update the text, maps and <br />exhibits in the application. Please assure that the change in design conforms with Rule 4.10.3(1)(c). <br />12. Please correct Table 49A to sum the "Total Volume" column for the Eastern Mining District Table. The <br />Division's sum for this column is 20,505 cubic yards, instead of 5 cubic yards as shown on the revised <br />table. <br />13. Please tie the contours of the proposed CRDA expansion into the existing contours of the current RDA <br />on the Final Grading map. <br />14. Please define where the 50ft. interval to the first bench on the north face of the CRDA initiates from. <br />This was not clearly defined on the north toe of the current RDA in the construction plans. Defining <br />where the 50 ft. interval is measured from will minimize discrepancies as the construction of the pile <br />progresses. <br />15. Please clarify. Existing RDA is approximately 3 million cubic yards of material. TCC refers to the <br />proposed CRDA expansion as 20 Million Cubic yards. Is the 20 million cubic yards of waste material in <br />addition to the existing 3 million cubic yards for a total of 23 million cubic yards, or will the total pile; <br />current RDA plus proposed CRDA, equal 20 million cubic yards total? <br />16. Rule 2.05.4(2)(d) requires a reclamation plan that includes a description of the operator's plan for <br />removal, storage and redistribution of topsoil, subsoil and other materials to meet the requirements of <br />Rule 4.06. Although TCC commits to replacement of salvaged topsoil, the text leaves the thickness of <br />topsoil required for replacement ill-defined. The text directs the reader to the Reclamation Cost <br />Estimate, or Map 29, or vaguely states that topsoil will be replaced. Please state in the text the average <br />topsoil thickness that will be replaced on the proposed CRDA expansion. The Division recognizes that <br />revised page 2.05-97.5 states that a total of 4.0 feet of cover and topsoil will be replaced over the graded