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Mr. William T. Davis - 10 - April 25, 1989 <br />Rules 2.05.6(6) and 4.20 <br />The application identifies areas of previous subsidence within and adjacent to <br />the permit area. As such, it satisfies the requirements placed upon surface <br />mining activities by our regulations. It would, however, be appropriate for <br />the applicant to commit to repairing aRy subsidence which occurred immediately <br />adjacent to underground workings intercepted by their surface strip mining. <br />Rule 3.02.1(5)(b) <br />The schedule for incremental posting of the reclamation bond does not appear <br />appropriately justified. Contrary to what is stated, there is a difference in <br />the difficulty/expense of reclamation at various times during the life of th~ <br />operation. There are, for example, areas of mining where overburden volumes <br />to be backfilled etc. are considerably larger than the figure used in <br />Section 2.05.4(2)(b). The amount of performance bonding posted must reflect <br />the worst case situation, i.e, the operation is abandoned at a point where <br />reclamation costs are at a maximum. The applicant should adjust his schedule <br />of bonding and demonstrate that it provides fora worst case situation. <br />Rule 4.19 <br />Intercepted underground workings could possibly contain Methane, Coal Damp and <br />other gases which might be dangerous to the miners, the general public and the <br />environment. Exposure of underground workings to air could present a <br />spontaneous combustion hazard. The applicant must obtain the approval of MSHA <br />and the Division of Mines as well as the MLRD for this operation, as required <br />~ by Rules 4.19(1 )fa ). <br />Sincerely, <br />~i [I.ti>~ G ~.~ti~ <br />James C. Stevens <br />Senior Reclamation Specialist <br />JCS/scg <br />5577E <br />