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Mr. Jack Henris <br />November 23, 2016 <br />Page 2 <br />m:\min\tc1\_teller\m-1980-244 cc-v\am -11\m-80-244-am-11-novflwupadeq2016-11-23.docx <br />6.4.5 Exhibit F – Reclamation Plan Map <br />N2. Drawing F-1. Contour elevation labels are missing on Drawing F-1 that would confirm <br />elevations discussed in the narrative portions of the application. Please include <br />appropriate contour elevation labels to determine elevations from this drawing. <br />6.4.21 Exhibit U – Designated Mining Operation Environmental Protection Plan <br />N3. Height Discrepancy. The following discrepancies need to be resolved to the Division’s <br />satisfaction: <br />a. Section 4.2 Topography and Elevation. On page 4-1, last paragraph there is a <br />statement that the maximum (natural) elevation of the project is at the crest of the <br />hill east of the East Cresson Mine (ECM) area which is approximately 10,450 feet <br />(amsl). <br />b. Section 5.6 Overburden Handling and Control. Page 5-17, at the end of second <br />paragraph, it is stated “Upon completion, the reclaimed ECOSA will blend with <br />backfilled portions of the East Cresson Mine areas.” The Division notes that based <br />on the USGS quadrangle map for the area, the elevation northwest of the peak ranged <br />roughly between 10,500 and 10,600 feet (amsl) before this area was mined. This <br />suggests the ECM / Altman backfill will not exceed an elevation of somewhere in <br />the range of 10,450 and 10,600 feet (amsl). <br />c. Section 12.4.2 Overburden Storage Areas. On page 12-9, fourth paragraph there is <br />a statement that the height of the ECOSA will increase from that approved in <br />Amendment 10 to 10,960 feet (amsl). This elevation is between 360 and 510 feet <br />above what would be expected between those statements in comments N3.a and b <br />above. <br />Volume III, Appendix 6 – Technical Memorandum <br />N4. Stability Analyses Height Discrepancies. Figure elevations: Figure 2 indicates the <br />maximum elevation of the ECOSA is 10,900 feet (compared to the 10,960 stated in <br />Section 12.4.2). Figures 3, 4, and 5 suggest the crest elevation is 10,950 feet. The <br />Attachment A stability model sections suggest a maximum elevation of 10,950 feet as <br />well. Please confirm the analyses were performed for the 10,960 foot elevation stated in <br />Section 12.4.2, or resubmit these analyses. <br />N5. New Required Slope Stability Analysis. Based on the above comments, it appears the <br />East Cresson Mine / Altman backfill area is proposed to be between 360 and 510 feet <br />above what was previously approved by the Division. As such, the Division requires an <br />additional north-south cross section be analyzed for stability through the reclaimed <br />Altman backfill area as indicated below by the red line: <br />