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A discussion in the permit text of how NECC will ensure the geotechnical stability of <br />the coal mine development waste piles, so that the piles will not fail during a heavy <br />rainfall or snowfall event and end up in the Purgatory River. How high would the <br />material be stacked on the ground, and given the storage locations, is there a need to <br />pile material more than one dump high? <br />• A discussion in the permit text of whether the coal mine development waste poses <br />any potential adverse impacts to surface water and ground water chemistry. Does this <br />waste create the potential for acidic runoff, and if so, does that create a problem for <br />NPDES compliance? Does this waste create the potential for adverse effects upon <br />groundwater quality? <br />• A plan for disposal of the coal mine development waste in the event the mine does not <br />re-open. Would the permittee still have to truck the waste up to the RDA? If the <br />waste would be returned to the mine and disposed of underground, we have rules <br />requiring plans for the disposal of coal mine waste underground be approved by both <br />us and MSHA, which would more appropriately be handled as a Technical Revision. <br />Please also include this information as permit text. <br />Considering the amount of material currently bonded to be hauled from the coal <br />stockpile areas and the final disposition location, please include as permit text a <br />discussion of how the cost estimate and bond would be adjusted to cover the costs of <br />removing the coal mine development waste from the coal stockpile areas to the RDA <br />in the event the mine goes into permanent cessation and final reclamation. This <br />discussion should also estimate an upper limit for the volume of material slated for <br />temporary storage, including any pond cleanings currently stored in coal stockpile <br />areas. <br />If you have any questions, please contact me. <br />Sincer , <br />2 <br />Kent A. Gorham <br />Environmental Protection Specialist III <br />KAG/Ahd <br />C-MR-01 _Cl 981012_KAG_03022010025513.doc