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in nature to other development waste previously stockpiled on site. Experience on site <br />dictates that the makeup of these materials and the analysis of the coal is not indicative <br />of the components of that would potentially lead to acidic runoff or adversely affect <br />groundwater quality. Each of the stockpile sites has the appropriate controls to capture <br />runoff applicable to the NPDES permit. The mine has a long history of stockpiling <br />coal without encountering spontaneous combustion. <br />application. Development waste is proposed to be disposed of in a Development <br />Waste Disposal Area (DWDA) south of Highway 12. The technical revision requesting <br />approval of the permanent disposal area will be submitted prior to the temporary <br />storage of development waste. <br />During mining the coal refuse will be disposed of permanently by conveying it to the <br />RDA. The RDA facility is described in detail in the later sections of this permit <br />If the rehabilitation reveals insurmountable mining issues there is the potential that the <br />mine would not be re- opened. If this occurs, the equipment necessary to convey the <br />waste to the RDA would be obtained through a short term lease agreement and all <br />stockpiled material would be conveyed to permanent storage in the RDA. <br />Bonding as described in RN -05 dated 01 -26 -2009 is in place to haul raw coal and clean <br />coal stockpiled on site to the development waste pile. Without the startup of mining, <br />the stockpiles will have minimal material to be relocated. The stockpiles are currently <br />empty with the exception of 1,180 ccy (1,400 Icy) of pond cleanings. Temporary <br />storage of 10,000 ccy of development waste in addition to the pond cleanings would <br />require relocation of 11,180 ccy (13,250 Icy) of material. The bonding in place is <br />adequate to cover the cost of relocating all of this waste to the RDA using a temporary <br />conveyor or haulage to a DWDA south of Highway 12 should one be approved. <br />Table 18a lists the volumes and costs associated with the stockpiles covered in the <br />bond calculations compared to the estimated cost to relocate the pond cleanings and <br />temporary development waste using the same rates per cubic yard. The current bond <br />amount of $33,410 to relocate the material is sufficient to cover the estimated expense <br />of $15,440 to relocate the temporary waste. <br />Table 18a Reclamation Bond Comparison with Temporary Stockpile Relocation Cost <br />Stockpile <br />Compacted Volume <br />Loose Volume <br />Haulage Cost <br />Estimate <br />(ccy) <br />(ICY) <br />($) <br />Southeast Coal <br />7,200 <br />8,532 <br />$8,071 <br />Northeast Coal <br />4,750 <br />5,629 <br />$4,722 <br />Raw Coal <br />5,900 <br />6,992 <br />$7,946 <br />Clean Coal <br />7,600 <br />9,006 <br />$12,671 <br />Total Current Bond <br />25,450 <br />30,159 <br />$33,410 <br />Temporary Waste <br />Raw Coal <br />10,000 <br />11,850 <br />$13,470 <br />Clean Coal <br />1,180 <br />1,400 <br />$1,970 <br />Estimated <br />11,180 <br />13,250 <br />$15,440 <br />Other coal processing support facilities are required and have been constructed at the <br />site. These facilities include buildings, roads, water system, sediment control system, <br />and preparation plant. Roads and sediment control structures are discussed in the <br />TR -52 Page 2.05 -4a Revised 4/20/2010 <br />