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-4- Roads The permit revision application includes a proposed access road, to be used to transport waste to the proposed upper waste pile site. This road would be an approximately 2,500 foot long cut-section, gravel surfaced road with grades up to 10 percent. Because of the inaccessibility of the proposed road alignment, the applicant has not completed a geotechnical investigation of the road corridor. In fact, the completion of a geotechnical investigation would require the pioneering of a roadway. The operator has requested that permission be granted to complete the geotechnical investigation and final design as the road is excavated. Construction of the existing roadways and surface facilities at the Mt. Gunnison No. 1 Mine has entailed extensive geotechnical investigation, including angering and materials testing. Numerous stability analyses have been completed to analyze proposed operational and reclaimed road configurations. The proposed roadway will involve many similar lithologic strata and slope stability situations. For this reason, the Division believes that the necessary material strength information probably exists with which to complete the necessary design exercise, as long as conservative assumptions are made, and later verified prior to final construction of the roadway. However, the Division believes that the operator should complete a thorough geological reconnaissance mapping of proposed roadway corridor and design projections, based upon the findings of that preliminary reconnaissance. For this reason, the Division believes it appropriate to impose the following stipulation upon approval of the permit revision application. Stipulation No. THE DIVISION DIRECTS WEST ELK COAL COMPANY TO COMPLETE A THOROUGH RECONNAISSANCE GEOLOGIC MAPPING OF THE PROPOSED UPPER WASTE PILE ACCESS ROADWAY CORRIDOR. THE APPLICANT SHALL PLACE SPECIFIC EMPHASIS UPON THE DETECTION OF SLOPE INSTABILITY EVIDENCE AND DRAINAGE CHARACTERISTICS OF THE PROPOSED ROAD ALIGNMENT. FURTHER, THE DIVISION DIRECTS WEST ELK COAL COMPANY, UTILIZING THE RESULTS OF THE RECONNAISSANCE GEOLOGIC MAPPING, AND EARLIER ADJOINING SURFACE FACILITY ROAD DESIGN STUDIES, IF APPROPRIATE, TO COMPLETE A PRELIMINARY ACCESS ROAD CUT-SLOPE STABILIZATION AND DRAINAGE DESIGN. THE MAPPING AND PRELIMINARY DESIGN SHALL BE APPROVED BY THE DIVISION, IN WRITING, PRIOR TO ANY DISTURBANCE OF THE ACCESS ROAD CORRIDOR. The above stipulated mapping and design efforts will produce a preliminary stabilization and drainage design for the upper waste pile access road at the Mt. Gunnison No. 1 Mine. However, actual site-specific geotechnical cut-slope