APPCOR10641

• Permit No: C1996084
• IBM Index Class Name: Application Correspondence
• Doc Name: Initial adequacy review
• Media Type: D
• Archive: No

• handling and storage of all overburden. Section 2.05.4(2)(c) requires the application to
contain a plan for backfilling and grading in accordance with 4.14. Section 4.14.2(1)(b)
requires backfilling and grading to the most moderate slope possible, not exceeding the
angle of repose or such lesser slope as necessary to achieve a factor of safety of 1.3.
Certain slopes shown on Map 2.05.4-1 aze quite steep, and may present stability concerns,
as well as reclamation concerns. For example, the area immediately adjacent to and just
west of Fill 5 has a slope angle of 33° (1.Sh:iv), and a slope length of 200 feet. The azea
within the "1999" blue lines that will lie between Fill 1 and Fill 4 has a slope angle of
22° (2.48h:1v), but a slope length of 400 feet and a southeast aspect.
The Division recommends the applicant redesign the slopes of the non-fill areas at the
surface mine so that south, southeast, southwest and west-facing reclaimed slopes are no
steeper than 3h:ly, that all other non-fill reclaimed slopes be no steeper than 2.Sh:ly, and
that the construction (material transportation, segregation, backfilling, compaction) of
these slopes will meet the 1.3 factor of safety required by Section 4.14.2(1)(b) of the
Regulations. Please provide this information.
68. In this same paragraph, it is stated that "a maximum of 1500 linear feet of pit will be
open at any one time. A variance is requested for the first cut through the ridge as it will
be left open for the second phase of the surface mine...".
It is assumed the performance standazd for which the variance is being requested is
Section 4.14.1(1)(a) of the Board's regulations. This section discusses the need for rough
[d backfilling and grading to follow coal removal by not more than 60 days or 1500 linear
Q', feet. However, this standard applies solely to contour mining, and does not apply to
~S mountaintop removal mining.
•~~ ~ ~ If Lorencito Coal Company wishes to apply for a variance from this standard for its
proposed contour mining operations, it should be more specific as to how much of a
variance it is seeking: an extra 60 days, or an extra 60 months? An extra 1500 linear feet,
or an extra ]5,000 linear feet?
69. It is stated on page 2.05-10 {1st paragraph) that "a solid berm will be le8 along the
6 outcrop to keep material from going down slope". Please provide the dimensions of this
~ ~t~„~"~ berm, ensuring Rs dimensions are sufficient to satisfy the requirements of Section
y 4.26.2(2) of the Board's Regulations.
70~~~r~ection 2.05.3(2)(a) of the Regulations requires the applicant to provide a "detailed
~~~~` i~ ~"` timetable sufficient to describe the various mine phases proposed by the applicant". The
4~ ~ ~ regulation goes on to state that "the maximum acreage proposed for each phase of the
y ~~~ ~~ operations within the permit area must be specified." Please provide this timetable.
~ See ~u,~t, 2,nS 3a
v~ 71. Sections 2.05.3(5), 2.05.4(2)(d) and 4.09.1(4) of the Regulations require a discussion of
~ ~~ how topsoil will be removed, segregated, stored and redistributed.
Under "Hollow Fill Construction", on page 2.05-10, there should be a discussion of how