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r <br /> Ms. Diane Delaney - 2 - February 7, 1992 <br /> TR No. 23 - Adequacy Concerns <br /> 1 . The proposal suggests that waste at the rock tunnel disposal site be <br /> covered and compacted at least annually. We are concerned that this <br /> schedule may be insufficient to prevent excessive accumulation and <br /> blowing trash during the summer months . We request that the schedule <br /> specify monthly coverage and compaction during July through October, and <br /> during other months as ground and snow conditions allow. <br /> 2. The proposed revision commits to completion of reclamation of the No. 1 <br /> Mine non-coal waste disposal by the fall of 1992. A reclamation plan for <br /> this disposal site was submitted within a Technical Revision approved <br /> October 18, 1985. That TR includes original , existing and proposed final <br /> reclamation cross sections. Unless specific design modifications are <br /> submitted and approved, the reclamation plan as approved within the 1985 <br /> Technical Revision is to be implemented. A copy of the referenced cross <br /> sections should be submitted for inclusion in the application. <br /> Page 19, Chapter V of the permit application states that reclamation of <br /> the site will follow the referenced plan, and refers to Exhibit II-B-4-d <br /> as showing the final configuration. This exhibit citation is apparently <br /> in error, and should be corrected. <br /> 3. We believe that the demolition and/or repair of damaged structures at <br /> Mines 3, 4 and 5 may need to be completed more rapidly than proposed. <br /> However, given the uncertain status of the operation at this time, it <br /> would not be prudent or realistic to establish a more specific timetable <br /> through this revision. If the mine is not sold, full reclamation will be <br /> conducted in accordance with a Board Ordered schedule. If the mine is <br /> sold, the successor permittee will need to identify the continuing <br /> operational uses (if any) for the outlying portals and associated roads , <br /> and a detailed schedule for repair, clean-up and reclamation will need to <br /> be established. <br /> 4. It is our understanding that oil cans and drums and other lubricant and <br /> hydraulic fluid containers are not approved for disposal at the rock <br /> tunnel disposal site. This question is not clearly addressed within the <br /> proposed revision. Temporary storage and final disposal of such <br /> containers should be described. <br /> DTM/ern <br /> 1188F <br />