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2. 05 .3 Operations Plan - Permit Area <br /> t- 1. Comment Rock Tunnel Refuse - The rock tunnel refuse <br /> pile has been reviewed as a technical revision during <br /> 1979 and 1980. The approval of the tunnel and its <br /> associated refuse pile stipulated the installation of <br /> ground water monitoring wells in and adjoining the <br /> refuse site. Further, monitoring results were to be <br /> collected and reported to CMLRD. The permanent program <br /> permit application should be amended to clearly state <br /> conformance with that stipulation. A list of the <br /> required water quality analyses is attached. In addition, <br /> data collected during the past year should be included <br /> within the application' s documentation. The applica- <br /> tion incorrectly states the rock tunnel refuse pile' s <br /> volume as 3200 cu. yds. on pages II-B-39 . The correct <br /> volume of 320 , 000 cu. yds. of waste rock does appear <br /> on page II-B-67. The appropriate correction should be <br /> made. <br /> Reply See Volume 5 Exhibit III-E-1 (left side) . <br /> This map shows groundwater monitoring wells in the <br /> rock tunnel refuse . AT-1 has been in place for over a <br /> year and as the record shows it has been Dry" , so no <br /> water sample. AT-2 A & B have been in place since the <br /> spring of 1981 (before that time not sufficient refuse <br /> was in place to warrant a monitoring well , less than <br /> 5 '+) . These two wells, one extending into the alluvium <br /> and the other to the bottom of the refuse have <br /> also been dry. <br /> Vol. 1 , Chap. II , Sec. B-3-C, Page 39 (Make typo <br /> correction) Page 44 (Add water monitoring <br /> explanation) . <br /> 2. Comment Coal Processing Waste Bank - The existing <br /> coal processing waste pile at Coal Basin has experienced <br /> at least one episode of significant slope instability. <br /> A surficial landslide damaged the conveyor system and <br /> neighboring portions of the pile. No mention of this <br /> past event is contained within the permanent permit <br /> application documents. <br /> The summary of geotechnical analyses presented on pages <br /> II-B-70 through 80 , is inadequate to satisfy the require- <br /> ments of Rule 2 . 05 . 3 (6) (c) . The application must contain <br /> the details of the geotechnical and stability analyses <br /> of the site and proposed waste bank. The large volume <br /> and hazard potential of the proposed pile necessitate <br /> careful analyses and engineered designs. <br /> t� <br />