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Mr. Joe Carpio - 2 - May 11, 1987 <br />5. Revised Map 10- Mine Plan indicates a portion of the area proposed to be <br />mined located in the NW/4 NW/4 of Section 28 is federally owned coal <br />which La Plata Coal does not have legal right to mine. The portrayal of <br />mining this area must be deleted from the map with the mining sequence <br />modified accordingly for the proposed permit area. <br />Application Section 2.04 (Rule 2.04.12 - Prime Farmland) <br />6. La Plata Coal has requested a negative determination on the presence of <br />prime farmlands. The letter from the Soil Conservation Service (SCS) <br />(Exhibit 11) states "... we feel that your pond may (emphasis added) <br />extend into some areas that may (emphasis added) qualify for prime <br />farmland because of its slope La Plata Coal needs to further discuss <br />this matter with Doug Ramsey of the SCS and obtain a more definitive <br />answer as to whether the lands are prime farmland. If identified as <br />prime farmland, the information requested by this rule and Rule 2.06.6 <br />must be submitted. <br />Application Section 2.05 (Rules 2.05.3 - Operation Plan; 2.05.4 - <br />Keciamation Nian) <br />7. The backfilling and grading plan in the permit application contains <br />contradictory information regarding the proposed backfilling plan. <br />Portions of the text describe a backfilling plan which would return the <br />disturbed areas to approximate original contour; other portions describe <br />a plan to backfill only a portion of the highwall or face-up. The <br />application also contains statements regarding the existence of "natural <br />highwalls" within the mine area and the difficulty in achieving a static <br />factor of safety of 1.3 for areas backfilled to angle of repose. The <br />proposed post-mining topography map depicts little or no backfilling of <br />the east and west portions of the portal bench, substantial backfilling <br />and over steepening of slopes in the center of the portal bench, and no <br />backfilling of the access road cut or lower facilities area. Based upon <br />the Division's calculations, the proposed backfilling plan results in a <br />substantial material deficit. <br />Based on the above, the applicant needs to amend the backfilling and <br />grading plan portion of the text and the post-mining topography map to <br />describe and depict an appropriate, consistent backfilling and grading <br />plan for the portal area, access road cut, lower facilities area, and <br />sediment pond. Specifically, the following items need to be adequately <br />addressed. <br />The applicant needs to prepare an appropriate stability <br />analysis of a complete highwall backfill scenario (the <br />"A.O.C." case). If the analysis results in a static factor <br />of safety of 1.3 or greater, the proposed backfilling and <br />grading plan must be amended to provide for complete <br />backfilling of the exposed highwall. If the stability <br />