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Ms. Christine Johnston <br />Mountain Coal Company <br />Page 16 <br />April 14, 1997 <br />separate cover, to adequately address his concerns." Dr. Pendleton, having reviewed the <br />materials submitted by MCC, is of the opinion that the Division's concerns have still not <br />been adequately addressed by MCC. Dr. Pendleton's opinion regarding this technical <br />memorandum, and his basis for it, are summazized below. <br />§ 1.0 Background, Page 1, ¶ 2 <br />Golder Associates states; "Post construction as well as post reclamation slope stability <br />analyses were performed on critical sections along the main access road, substation site, <br />and the shaft site. Slope stability was evaluated for slope failures that may have <br />significant impact on the constructed facilities, as opposed [o shallow soil creep, which <br />will be addressed by MCC as a maintenance issue." <br />This statement requires extensive clarification before the Division can render an opinion <br />regarding its validity. First, it implies that short term operational concerns are the only <br />timeframe of concern in permit review. Secondly, it implies that "shallow soil creep" is <br />acceptable to the Division as "a maintenance issue". As observed in the Division's <br />original adequacy comments, it is the mandate of the Division to assure that a reclaimed <br />conftguration is completed by MCC which will support the beneficial use of the post- <br />mined site. The Division cannot approve a reclamation plan prone to pervasive "shallow <br />soil creep" as an acceptable reclamation goal. Before the Division could render an <br />opinion regarding this statement, MCC, Golder Associates and the Division would have <br />to agree upon the time frame of concern in permit approval and working definitions of <br />"significant impact on constructed facilities" and "shallow soil creep". <br />Golder Associates closes this paragraph by stating; "...a geotechnical investigation has <br />been proposed which will obtain soil strength parameters from laboratory testing that can <br />be used to better define the slope stability variables in specific areas." Subsequently, MCC <br />submitted and received approval for MR 210 to conduct additional sample collection <br />within the SGFA. The Division's original adequacy comment #71 stated; "The Division <br />can approve PR-07 only after acceptable design detail, including construction methods, <br />specifications, and stability analyses, have been completed to demonstrate the stability of <br />both the operational and reclaimed configurations for all the proposed facilities." No <br />approval of PR-07 can be granted by the Division prior to the collection and analysis of <br />the additional geotechnical samples, and the subsequent acceptable revision of the stability <br />analyses, mine plan and reclamation plan, if appropriate, based upon that site specific <br />information. Further, had the Division had the opportunity to complete a thorough review <br />of the extensive geotechnical information submitted by MCC simultaneously in response <br />to PR-07 adequacy comments, the Division would have recommended additional sample <br />collection and monitoring instrumentation installation. The facilities approved as MR 210 <br />will probably not provide sufficient geotechnical information with which to support the <br />approval of the mine plan and reclamation plan as currently proposed by MCC. [n the <br />