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Alternative criteria and specifications were used during the design of haul roads. These criteria and specifications were approved by the Division following an analytical demonstration that the roads would be environmentally sound and reclamation could be achieved. The proposed criteria and specifications pertain to haul road F 1, a portion of which is built on a 110 foot fill embankment, and was constructed prior to August 3, 1977. Details of the road construction and design aze located in Volume 11, Tab 12. (4.03.1(1)(e)). The Division has approved the temporary alteration or relocation of a natural channel drainage way located on Haul Road F 1. The applicant has successfully demonstrated that the natural channel drainage will not be permanently blocked, no significant damage will occur to the hydrological balance, and no adverse impacts will occur to adjoining landowners. The drainage way to be affected is crossed by the 110' F1 Haul Road embankment, which was permitted with the condition that it would be removed upon the cessation of mining. The road was constructed prior to August 3, 1977. A stipulation (No.17) was placed on the permit in 1981 to require an annual inspection of the embankment, or an inspection following any storm whose backwater elevation exceeds the projected 10-Year, 24-Hour maximum storm events projected backwater elevation of 6,941.1 feet. The fill embankment has been removed and the natural drainage has been restored as part ofthe final reclamation activities at the site. Stipulation No. 17 has been complied with and removed from the permit. The applicant has made a demonstration, based on site specific precipitation rates, percent of grade, and soil properties that use of altemative specifications for culvert and bridge sizing will not result in increased erosion. The Division, therefore, approved the use of the alternative specifications for the haul road culverts. The culverts were located such that drainage is routed to existing major drainage ways which aze incised to bedrock. (4.03.1(4)(e)(vi)). B. Access Roads At the Seneca II Mine, there were approximately 2.2 miles of access roads. These access roads have been reclaimed. C. Light-Use Roads There are approximately 3.5 miles ofexistinglight-use roads that are shown on Exhibit 13-2A as South Road, and South Roads A and B. These roads are only used on an intermittent basis for monitoring and periodic maintenance of monitoring facilities and reclamation areas. SCC has designed and constructed the postmine light-use roads to comply with applicable performance standazds. Landowner requests in writing, that the roads remain open for further use, have been received by the Division. 12