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It must be recognized that these piles are under construction, and conditions change. Ditch designs in <br />the permit document are for the final reclaimed configuration. Some of the ditches mentioned in the <br />inspection report are rough cut ditches, intended to direct water to stabilized channel off the fill, but <br />they are not the final configuration. Benches are still being worked and re- worked. The ditches will be <br />final graded after the terraces achieve their final slope configuration. <br />The day prior to the site inspection and the day of inspection yielded a total of 1.1" of rain. That is a <br />significant amount of water. The site was configured to effectively manage the rain event. All run -off <br />from the pile was contained in a sediment pond. <br />There must be an allowance for the continually changing nature of construction, and that conditions <br />can change from day to day. Further, the slopes on the terrace ditches have a design slope of 1.50% to <br />5.0 %. However, the ditches that have a design slope of 5% have not been constructed, so what is <br />actually constructed in the field is closer to a 2% slope configuration. That means in a 10' section, you'd <br />expect a drop of 0.2' or 2.4 ". Rough cut ditches may have an overall grade of 2% but there will be <br />some low and high points along the flow line. Minor accumulation of water along a terrace ditch is not <br />considered a problem during construction of the pile. <br />The Operator believes it has managed the coal mine waste piles in a responsible manner in accordance <br />with the DRMS Rules and the permit application package. The Buckhom Geotech Reports contained <br />in the permit application package clearly indicate the need to end -dump and dry the gob material prior <br />to placement. The Operator works expeditiously to re -handle the end - dumped material and place and <br />compact it into the gob pile in a controlled manner. The DRMS should be able to recognize the work <br />in progress at the gob piles and not expect that all internal drainage ditches be at final grade and <br />configuration. <br />Sincerely <br />Wm. Bear Jr <br />