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J • • • -9- 2. :9ith respect to the nature of thc- proposed bench and fill, there is a difference as to whether it is designated as backfilling~and grading or excess spoil. The applicant must make this distinction and address all appropriate concerns. Backfilling and grading of the bench material e:'ould require that the applicant meet the requirements of Rule 4.14 and demonstrate that a minimum static safety factor of 1.3 has been achieved. 3. For the overburden storage area, the. applicant must demonstrate that this qualifies as excess spoil. In addition, the pile must be designed and constructed according to the requirements of Rule 4.09, and is required to achieve a Long- term static safety factor of 1. 5. 4. The applicant has not determined the precise configuration of the bench or overburden storage area. The applicant needs to provide this information. 5. It is suygested in the application that the post miring configuration, will consist of slopes that are less steep than those that existed prior to mine development. This cons titues a variance from, approximate original contour. The applicant must therfore submit a request fora variance from approximate original contour pursuant to Rule 2.Or;,S. The applicant must also provide sufficent analysis to demonstrate that the post mining configuration :.~i11 meet the stability requirements of Rule 4.14. XVIIZ. Coal Processiny 4/aste and Non-coal Processiny [:'aste - Rules 2.05.3 ' 2.05.9(2)(f), 4.I0 and 4.I1 Deficiencies: 1. The Division has included a memorandum from Jim Pendleton of the Division staff with this document. The memo outlines the results of Dr. Pendleton's technical review of the stability analysis for the proposed waste pile. Also included within the memo are suggestions for further work. to be underta}:en by tl-,e applicant prior to final approval of the penrut, and a sugyesticn for a stipulation to be attache-d to the permit. The applicant must address those concerns which were identified in items 1 and 2 on page 2 of the memorandum prior to permit issuance. 2. Also with respect to the attached memorandum, the applicant must consic.'er nn~l anticipated changes in the construction or configuration of the waste disposal pile. It must be determined, by the applicant, whether the stability analusis for the pile is still valid and sufficient documentation must be supplied to confirm the validity of the analysis. All supportiny documentation rncrst be incorporated into the permit application. :i 1.\". Idi r:e Foci 1 i ties, Coal llandliny Structures, Support Fa ci li ties - Rut rs_ 2.05.3(3), 2.05.3(7) and 9.04 Deficiencies 1. The applicant needs to describe, for each of the follo~wi.n9, the construction and/or modification, use, maintenance, and removal: mine office, bathhouse, ware- house, supply area, stackers, preparation plant, hopper, mine fans, portal structures, explosives bunker (which also needs to be located on the map), sub- station, raw and clean coal stockpiles, coal processing waste pile, and parking area.