APPCOR13434

• Permit No: C1981038
• IBM Index Class Name: Application Correspondence
• Doc Date: 3/21/1978
• From: US ENVIRONMENTAL PROCTECTION AGENCY
• To: US GEOLOGICAL SURVEY
• Media Type: D
• Archive: No

•
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d. Representative locations along slopes of fill benches..
4. Continuous monitoring of precipitation at the mine ,site.
5. Visual inspection of all diversion channels for signs of
erosion and deposition with photographic documentation conducted as
often as necessary but not less frequently than during ever, major on-
site inspection required by Public Law 95-57 (Surface Mining Control
and Reclamation Act of 1977). '
EPA takes this opportunity to again share with you and
its concern that the post-mining configuration of the distu
not yet been thoroughly evaluated. The mining plan indicat
benches and drainage system constructed throughout the dist
will also be the post-mining configuration. Though no stab
of this configuration is presented, it must be concluded, t
that the upper basin diversion structure would have to be p
protect these benches from overland flow. We have previous
that the upper basin diversion structure cannot be permanen
stability and role in the modified drainage system is adequ
mented (through operational monitoring). If the upper bast
channel cannot be maintained, then the bench area must be m
for renewed drainage and overland flow. Since the permanan
upper basin diversion is in question, the mining plan Shaul
past-mining land surface configuration that permits flow of
drainage through the disturbed area and requires minimal ma
Paragraph (a) of part 717.14 of Title 30, Code of Fed
tions does recognize that roads and support facilities exi
to December 13, 1977, might have to be regraded "to the er
feasible by the regulatory authority." However, the feast
based on the availability of backfill material and the res
lity of the post-mining land surface configuration. The r
also indicate that cut and fill terraces are to be left (c
when they are appropriate substitutes for lower grades. E
materials must be considered "available" since these mater
those to be used to fill in the upper diversion if that di
not be permanent.
We recognize that sufficient flexibility exists withi
and regulations to allow the applicant to demonstrate that
tions of the post-mining land surface configuration will m
requirements. Until such demonstration is made. we believ
cant must agree to backfill and regrade the disturbed area
stability, adequate drainage, and the most moderate slope
eliminate any highwall along roads, mine entry faces or of
(30 CFR 717.14 (a) (2)). We, therefore, recommend that th
stipulation be included in any approval of the subject min
your staff
bed area has
s that the
rbed !area
litylanalysis
eoretically,
rmanent to
y agreed
until its
tely!docu-
diversion
de suitable
y of', the
include a
overland
ertain varia-
t pertinent
theappli-
o achieve
ssible to
r areas
following
g plan:
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