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<br />for the faces of the 21 proposed spoil fills. Areas adjacent to fills #2, #3, #5, #8 and #9 <br />appeaz to be steep enough to present a slope stability concern. Based upon the brief <br />description of backfilling presented within the application, it is not possible for me to <br />deduce the degree of effort to be applied to the placement of this material. Therefore, it <br />is difficult for me to assess the probable shear strength of the backfilled spoil to be placed <br />within the mined area. For these reasons I believe it appropriate for the Division to direct <br />the applicant to provide an analytical demonstration of the anticipated backfill mass to <br />demonstrate compliance with the Rule 4.14.2(1)(6) requirement "to achieve a minimum <br />static safety factor of 1.3". The geotechnical information necessary to demonstrate <br />compliance with the requirements of Rule 4.09 addressing the stability of the proposed <br />fills should provide the parametric information necessary to complete this analysis as well. <br />104. Reclamation plan, perzrtit application page no. 2.05-59. Please define what the topsoil <br />redistribution thickness will be throughout the various areas of the mine. <br />105. Permit application page 2.05-59 indicates that reclaimed roads will be ripped to a depth <br />of 18 inches prior to topsoil application or "loosened". Please define what LCC means <br />by "loosened". (Chisel plowed to a specific depth?) <br />106. LCC proposes to install contour furrows along the highwall reclamation area, permit <br />application page 2.05-63. Figure 2.05.4-19 has been included to show a typical design <br />for the furrows. Please elaborate on how the design was determined; contour interval, <br />height of furrow. <br />107. Please provide plans for the sealing of the portal areas (Sections 2.05.4(2)(8) and 4.07). <br />Please note that these plans must be consistent with 30 CFR 75.171 l (7/1/96 or later). <br />108. Table 2.05.4-1 states that 51.8 acres of riparian area will be disturbed by topsoil <br />stockpiles. The Division believes this to be an error as Exhibit 10, Table V-1, indicates <br />that less than 1 acre of riparian community would be disturbed. Additionally, locating <br />topsoil stockpiles in a riparian area would conflict with Rule 4.06.3(2). Please bring this <br />acreage into agreement with actual planned disturbance. <br />Rule 2.05.5 Postminin¢ Land Uses <br />109. Please revise the statement on permit application page 2.05-75A that states, "A change of <br />land use following mining has been approved for some disturbed areas." At this point in <br />time, the Division has not approved a change in land-use. Please revise this statement. <br />Rule 2.05.6(1) Air Pollution Control Plan <br />1 l0. The applicant will need to provide the Division a copy of the Air Pollution Control <br />Division emissions permit (or other equivalent form of approval) for review and inclusion <br />into the application materials before any coal mining operations may begin. <br />