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9. The Division summed the direct costs included in Exhibit 28, pages 159-165 <br />and calculated a total of $155,907.00. The direct cost total on page 158 in <br />the summary is shown as $204,668.00. Please explain this discrepancy. <br />Also, costs associated with sealing the dewatering holes and for power line <br />removal were not found. Please review and provide an updated cost <br />estimate as necessary. [Rule 2.05.4(2)(b)] <br />10. Beginning on page 2.05-54, please submit additional permit text <br />narrative to comply with Rules 2.05.4(2)(f) through (h), including but <br />not limited to, specific details for the Bates Portals. <br />11. Due to its proposed location outside of areas where disturbed runoff will be <br />routed to a sediment pond, subsoil storage pile #1 would be designated as a <br />"small area exemption", as implied by Rule 4.05.2(3)(b)(i). Please submit <br />permit text narrative and the required sediment demonstration <br />showing how effluent limitations will be met for surface runoff from <br />subsoil storage pile #1. Alternative sediment control measures are <br />appropriate for this area. Please also review currently approved maps, <br />like Map 12, which show previously approved SAE's and use <br />consistent annotation on the appropriate sheet of Map 11 to clearly <br />show all SAE's. <br />12. The access road south of the coal silos is being extended and a short <br />section of new light use road is also being proposed near this area. A new <br />section of light use road is proposed at the West Portal, as shown on Map <br />12. Please provide the information required under Rule 2.05.3(3)(c) and <br />Rule 4.03, as necessary, for these three sections of roads. Permit text <br />narrative describing the construction, use, maintenance, and <br />reclamation of these new roads is required. Access roads also require <br />certification after construction in accordance with Rule 4.03.2(1)(f)(i). <br />13. The Division suggests that a new haul road not be proposed to access the <br />topsoil and subsoil storage areas proposed under TR-55. Access corridors <br />are implied for this kind of work and have not been historically permitted as <br />haul roads, unless the road is meant for purposes other than only access to - - <br />construct the storage piles. <br />14. Division of Water Resources (DWR) comments were provided to you <br />previously (electronic comm. 3/4/2011) Please ensure that the required <br />permitting is completed with DWR for the mine dewatering wells. <br />15. Division of Wildlife (DOW) comments were also provided to you previously <br />(electronic comm. 3/4/2011). Please ensure that surface disturbance <br />markers are established prior to the start of any proposed <br />construction. Also, additional power poles are proposed. Figure 17 and <br />page 2.05-57 to 58 discuss the use of raptor proof power pole design (as per