2009-10-13_REVISION - C1982056 (2)

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will be included in the quarterly refuse pile reports. Appropriate descriptive text and supporting materials have been revised to include these monitoring details. 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(5a), 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. The Division has conducted a reclamation cost estimate (RCE) using values for the entire proposed CRDA expansion. The Division has estimated the cost to reclaim the proposed activities for the entire 140 acre CRDA expansion is $1,014,846.00. The Divisions's RCE is included with this letter. Response: TCC's bond reclamation cost estimate took into account the consideration that bond monies have already been posted for the existing Refuse Pile, which includes the entire eastern side (approximately 40 acres, part of which is partially reclaimed at this time) that will be redisturbed by the proposed CRDA Expansion. This existing bond, along with the calculated bond coverage for a 50 acre area, addresses bonding for the maximum anticipated area of disturbance that will exist at any given point in time. It is reasonably anticipated that the CRDA Expansion will reach a point where the new disturbance associated with soil and cover material stripping and drainage construction will be offset by reclamation of completed benches and the sloping top surface of the pile, as it progresses from north to south. TCC, therefore, is applying a cumulative bond schedule to the proposed CRDA expansion. TCC is aware of the constraints inherent in a cumulative bonding approach, and will work with the CDRMS to delineate bonded areas and maintain adequate bond coverage for all activities. The relevant revision text has been reviewed and revised, as appropriate, to clarify the bonding approach. 9. Permanent Ditches RDA-4 and RDA-3 are shown constructed into the existing Refuse Disposal Area (RDA). Permanent drainages must conform with Rule 4.10.3(2), Rule 4.09.2(7). The permanent ditches cannot be constructed on top of refuse material: TCC has an existing permanent ditch downslope from proposed RDA-3 and RDA-4. TCC needs to direct flow from the refuse pile to RDA-1c and RDA-1b and assure that these ditches continue to be appropriately sized for the additional drainage area. Response: The revised grading plan (Drawing C-101) shows that the existing ditch that runs along the western margin of the coal refuse disposal area has been re-designated as RDA-3. The revised grading plan also shows that flow in RDA-1 will be routed to the RDA-1 system. The SEDCAD demonstration for RDA-1 (which includes RDA-lb, RDA-1 d, RDA-le and RDA-If) has been updated, and revised ditch designs are provided with these responses Drawing C-102, Initial Sequence Grading Plan, shows Ditch RDA-4 (note the change in ditch designation with this revision), a temporary ditch that will route runoff from the undisturbed area above the southern limit of the fill, and from the top of the fill area, around the southern limit of the fill. An alternative design for RDA-4, evaluated for the 100-year, 24-hour storm event, is also