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Ms. Christine Johnston <br />Mountain Coal Company <br />Page 15 <br />April 14, 1997 <br />addition, soil testing should be carried out at critical locations and, piezometers, <br />inclinometers or other ground evaluation techniques should be installed to monitor <br />ground conditions over the life of the facilities." <br />"Summary of Sylvester Gulch Geotechnical Investigations" by MCC - 2/97 <br />This tabular summary, labeled as prepazed by the "West Elk Mine, references an <br />additional investigation performed by Golder Associates in July of 1996. No <br />report is provided. The tabular reference states; [Golder Associates] "Reviewed <br />previous work and concurred with Tift and Clanton assessment. Perfortned <br />reconnaissance of site and identified slide areas impacting proposed development." <br />This tabular summary also provides summaries of all the "Sampling and Testing <br />Programs" performed specifically in regazd to the SGFA proposals. Finally the <br />summary presents 22 "Historic Strength Data" results for materials tested "For <br />West Elk Mine" and 12 "Current Strength Data" results for material samples from <br />the SGFA subjected to laboratory shear testing. <br />"Sylvester Gulch Development Project - Geotechnical Investigation Program" by Golder <br />Associates - 1/97 <br />The most contemporary report included in the MCC response to geotechnical <br />adequacy comment packet is a January 29, 1997 letter to MCC from LeeAnn <br />Bush, P.E. And Chazles H. Robinson of Golder Associates. This letter, authored <br />following the receipt of the Division's adequacy comments and the meeting <br />between the Division, MCC and Golder Associates' representatives, and later <br />submitted as MR210 by MCC, proposes the conduct of additional sampling, <br />piezometer installation, and laboratory materials testing within the SGFA. <br />Unfortunately, at the time of the Division's review and approval of MR210, the <br />bulk of the additional PR 07 geo[echnical responses had not been reviewed. Had <br />the Division had this opportunity it's adequacy comments regarding MR 210, <br />particulazly those recortunendations for additional short term and long term <br />monitoring and instrumentation, would have been different. <br />"Sylvester Gulch Facilities Area Slope Stability Technical Memorandum" by Golder <br />Associates -March 3, 1997 <br />MCC observes on page 12 of its "Adequacy Responses to PR-07 "letter that this <br />Technical Memorandum from Golder Associates [o Eric Mende, "...clazifies the slope <br />stability analysis performed on the SGFA (post-construction and post-reclamation)". <br />MCC further states; "The slope stability analysis included in the application package <br />remains valid." MCC closes it's response to adequacy question #71 by stating; "This <br />memo and other supporting information have been sent to Dr. Jim Pendleton, under <br />