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Preliminary Adequacy Review <br />Bear Coal Co., Znc. - Bear Mine <br />Page Seven <br />2.05.4 (2) (c) Backfilling and Grading <br />1. The application states; "Backfilling the portals will entail filling ten to <br />twenty feet out by a double solid block wall which will be constructed in portal <br />entries." (Page 70) In accordance with Rule 4.19, the portal areas should be returned <br />to approximate original contour, if it can be accomplished with a minimum static <br />slope safety factor of 1. 3. The applicant must perform a stability analysis of the <br />proposed backfill configuration in order to demonstrate conformance with Rule 9.14.2 <br />(1)(b). This stability analysis must consider both portal highwall cut slope as well <br />as the portal bench fill embankment. <br />2. The final topography map included in the application does not indicate the <br />changes that will occur on the site as a result of the new highway and the relo- <br />cation of the river channel. These changes must be submitted. Any changes in the <br />reclamation plan due to the construction of the highway must be provided. (See <br />Sections 2.05.9(a,b,c,d,and f).) <br />3. Zt is not clear from the application how the old coal waste site immediately <br />to the West of the office-shop area, adjacent to the sediment pond, will be reclaimed. <br />Is the material to be hauled off as a part of the facilities clean up, or is it to <br />be covered with soil or non-toxic fill material and seeded? There appears to be a <br />potential that the waste pile is in the path of the proposed river channel relocation. <br />If this is the case, the pile will have to be removed. The applicant should explain <br />how this problem will be resolved, and whether Bear Coal Company or the State Highway <br />Department will be responsible. <br />4. It has come to the Division's attention that ARCO plans to install a fresh- <br />water pond at some future date within the area presently occupied by the Bear Mine <br />surface facilities. Zf any details regarding the exact location and size of the pond, <br />and the proposed construction date are available as it may pertain to this permit <br />application, they should be provided to the Division. <br />2.05.9 (2) (d) Topsoil <br />1. From what portion of the permit area was t]~e topsoil stripped that is presently <br />stockpiled? Was just the A horizon stripped? What are the characteristics (i.e., <br />suitability of the stockpiled topsoil as required by 2.09.9(1)(b))? This information <br />must be discussed to comply with 4. 06.2(2)(a). <br />2. The Division requires that the applicant supply estimates of volumes of avail- <br />able topsoil and acreage of disturbance to be topsoiled to allow the determination of <br />approximate coverage of the reclaimed area. <br />3. The applicant must be more specific with respect to the additional topsoil <br />proposed to be hauled from Paonia Reservoir. What is the actual source of the <br />material? Provide analyses of the material to determine suitability. Please out- <br />line the agreement and list the other parties involved in the purchase of the <br />topsoil. <br />.L <br />