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Ms. Christine Johnston <br />Mountain Coal Company <br />Page 10 <br />April 14, 1997 <br />In order to determine the estimated reclamation costs for removal of all buildings and <br />structures, DMG is in need of the composition and dimensions of the superstructure, <br />foundation, and footing for every structure shown on the "General Arrangement of Site <br />Layout Showing Sinking Facilities and Services" map, the flocculant storage building, and <br />the power distribution equipment. Please include the width, length, and height or <br />thickness for each structure. <br />A detailed plan, with supporting maps and cross sections, for backfilling and grading of <br />all disturbed azeas needs to be provided. The plan should include a material handling plan <br />which indicates the bank volume, pre-mining location, operational (post-construction) <br />location, and final (post-reclamation) location for all material which will be used to <br />develop the SGFA, including that used to construct roads, yazd areas, ponds, and benches; <br />any material used in the relocation or realignment of roads; and the volume of material <br />removed to develop the ventilation shafts. <br />Please be advised that, as plans for the SGFA aze revised during the review process, the <br />Division may have additional questions prior to completing a cost estimate. <br />56. DMG requested a detailed description, with cross sections and maps, of the methods <br />proposed to seal the ventilation shafrs. MCC responded with a general description and <br />no cross sections or maps. Please provide a detailed description, which includes <br />illustrations, of exactly how the shafrs will be sealed. MCC states that a concrete seal will <br />be installed on a steel structure below the collar concrete. How will this structure be <br />installed, what aze the details of its construction, what sort of equipment will be required? <br />MCC's proposal does not appear to be in compliance with the requirements of Section <br />4.07.3(1), which requires (for boreholes not completed to aquifers) sealing by replacing <br />cuttings or other suitable media in the hole and placing a suitable plug 10 feet below the <br />ground surface to support a cement plug or other media approved by the Division to <br />within 3 feet of the ground surface. Please revise the text to include a plan for sealing <br />the boreholes in compliance with the referenced rule. In addition, MCC should include <br />a proposed plan for sealing the borehole, in accordance with Section 4.07.2(2) in the event <br />that aquifers aze intercepted. <br />57. DMG's original comment indicated there would be 80,000 CY of surplus material at <br />reclamation of the SGFA, and asked MCC to clarify an apparent material balance <br />discrepancy. MCC now estimates 168,000 CY of material will be brought in and used <br />to develop the SGFA, but does not include specific plans for redistribution of the surplus <br />material, as described in Comment 55. <br />58. MCC estimates the total SGFA disturbance will be approximately 62 acres. Based on <br />Map 53B, Sylvester Gulch Facilities Plan, DMG measured a disturbance of 76.5 acres. <br />