2009-10-13_REVISION - C1982056 (2)

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stripped and stockpiled for this project. Please refer to the revised text descriptions, and updated materials in Exhibit 26C, for clarification. 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 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. Response: As noted in the previous response, design volumetrics for the pile have been reviewed and corrected, as appropriate, with appropriate revisions to the descriptive text and supporting materials. It should be noted that the plans and permit approvals for the existing RDA reflected recovery, stockpiling, and replacement of 0.7-0.8 feet of soil materials on completed refuse disposal areas. In addition, where cover and soil materials have already been replaced on the eastern slope of the existing RDA (designated as Area A2 in Exhibit 26C-A1), these materials will be removed and directly placed on the western side of the existing RDA, to complete reclamation of this area. Given that the CRDA Expansion will incorporate the existing RDA, cover and soil materials previously removed and stockpiled for reclamation will also be available for reclamation of the combined refuse pile area. Recovery of 3.5 feet of suitable spoil materials, rather then the 2.5 feet required for placement provides several positive benefits; it increases the available coal refuse placement volume; provides additional suitable cover material to address any deficit in materials for the existing RDA; may be used to selectively increase cover or soil depth on specific areas of the completed CRDA Expansion in order to achieve targeted reclamation objectives (ie: shrub or tree plantings; and provides some supplemental material to address the potential for large boulders and rock in the recovered spoil materials (rocks and boulders would be graded to the side and left on the surface as wildlife habitat). The referenced text section on Page 10 of Exhibit 26C has been revised to include a general volumetric balance for cover and soil material handling to demonstrate that adequate material will be available to meet the cover requirements, without a significant excess of material. 4. Since construction of the pile is presented in 2 phases, please provide amass balance showing the topsoil and cover (spoil) volumes if the construction of the CRDA were to be stopped after the Phase I development Response: Designation of discrete phases is not an accurate depiction of how the CRDA expansion will occur, and references to phasing have been removed from both the text and maps. The rate of construction for the refuse pile will generally be determined by both mining conditions and coal market conditions, may vary, and will be dynamic (similar to our current refuse pile construction and placement practices). As described in the text, soil and cover material stripping and drainage construction will be scheduled and sequenced to stay well ahead of the advance of refuse placement at all times. The maximum CRDA expansion configuration may, or may not, be reached over the overall mine life (Foidel Creek and Sage Creek), however, it is shown in the designs to provide an accurate depiction of the maximum anticipated capacity and footprint configuration, and to illustrate the handling of drainage from the upper surface of the CRDA. The upper surface of both the active benches and the