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If the applicant's proposal for backfilling the affected area consists of <br />returning the portal area and access road cut to approximate original <br />contour, then all reference to alternative backfilling schemes need to be <br />removed from the application. In addition, Map 9 will need to be amended <br />to depict the approximate original contours of the portal area, access <br />road, and lower facilities area. Exhibits 15 and 16 will also need to be <br />amended to demonstrate the stability of the proposed backfill and the <br />material quantities needed to achieve the proposed contours. <br />The Division understands the applicant's concern with regard to potential <br />stability problems which could result from complete backfilling of the <br />portal face-up area and steep road cut areas. If the amended stability <br />analysis performed for the Approximate Original Contour (AOC) backfill <br />scenario results in a static factor of safety less than 1.3, then an <br />alternative backfilling scheme would be appropriate. The mine site <br />appears to qualify fora variance from the requirements to restore the <br />affected area to AOC based upon the steep slope condition of the area. <br />The applicant has briefly addressed steep slope mining and AOC variance <br />requirements in Section 2.06 of the permit application, however a <br />specific request fora variance from AOC for the steep slope portion of <br />the operation has not been included in the permit application (addressed <br />in Rule 2.06.4 and 2.06.5). If the applicant elects to request a <br />variance from AOC, a stability analysis demonstrating that the <br />alternative backfilling scheme will result in a minimum static factor of <br />safety of 1.3 will need to be provided to the Division along with the <br />other demonstrations required by Rules 2.06.4 and 2.06.5. <br />If the applicant is contending that the existing configuration of the <br />portal bench constitutes AOC or that backfilling to the top of the <br />exposed coal seam constitutes AOC, then specific information regarding <br />the pre-mining configuration of the affected area must be provided which <br />clearly demonstrates that a natural cliff or "natural highwall" existed <br />along or immediately adjacent to the portal face-up and associated access <br />road prior to mining. <br />13. Page 2.05-25 of the permit application contains a brief reclamation cost <br />summary. Once the backfilling and grading plan for the operation has <br />been finalized and specific material quantities identified, there should <br />be sufficient data available to allow the Division to estimate the Cost <br />of reclamation for required bond coverage. In order to complete the cost <br />estimate, the following additional information needs to be submitted by <br />the applicant. <br />A. The dimensions (length X width X height) of each of the following <br />structures: Mine office, shop, fan, substation, warehouse, coal <br />crushing/handling/loadout facility, truck scale, overland conveyors <br />and supports, utility lines to be removed, and culverts to be <br />removed. <br />The type of material used to construct each building, i. e. wood, <br />cinder block, etc. <br />The specific acreage to be revegetated. <br />D. The estimated quantity and type of fertilizer to be used. <br />-7- <br />