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<br />PAR - C-80-007 - 13 - March 31, 1986 <br />VIII. Operation and Reclamation Plan <br />1. Exhibits 4.2.1.A and 4.2.1.8 need to be updated to accurately <br />depict current locations of surface facilities and especially <br />topsoil stockpiles. Map 4.2.1.8 also indicates that topsoil has <br />been respread on an area as of 1983. Please clarify if this is <br />true and specify what area it pertains to. <br />2. Page 4 of Exhibit 4.4.A indicates that topsoil has been respread on <br />several areas. Please verify this and submit a map and discussion <br />detailing what areas have had soil respread on them. <br />3. The post-mining topography map, (Exhibit 4.4.5.A) indicates <br />post-mining contours identical to pre-mining contours. In light of <br />the numerous slides and slumps that have occurred at the site over <br />the past five years and the permanent retaining walls and other <br />measures taken to mitigate and stabilize these areas, does this map <br />present an appropriate projection of post-mining contours.? <br />IX. Subsidence: <br />Several problems arise in considering the subsidence aspects of the <br />permit renewal application. The renewal application presents very few <br />changes from the original document. The application reflects the <br />changes in mine plan and subsidence monitoring accomplished within the <br />current revised permit, with one exception. During the past month, <br />West Elk Coal corresponded with the Division regarding some problems <br />implementing a portion of their approved subsidence monitoring <br />program. This very recent correspondence shou]d be added to the <br />Addendum Section of Exhibit 3.4.8.A of the permit renewal application. <br />The correspondence consisted of a letter from West Elk to Susan Mowry, <br />dated February 21, 1986, and a response from Susan to the operator, <br />dated March 4, 1986, with an attached memo from myself to Susan, dated <br />February 25, 1986 <br />A more complex problem arises concerning the Life-of-Mine Plan <br />subsidence projections. Because of recent judicial decisions, we will <br />need to complete a revised Cumulative Hydrologic Impact Statement <br />(CRIB) for "all anticipated mining". This will include all mining <br />anticipated to occur within the leases held by West Elk Coal. The <br />Life-of-mine Plan depicted on Exhibit 3.4.4.8.1 appears to depict all <br />anticipated mining, for purposes of the required CHIS. <br />The renewal application proposes to control possible subsidence impacts <br />to critical areas, such as the Dry Fork of Minnesota Creek and Lick <br />Creek, through the use of a plan of limited extraction. Exhibit <br />3.4.4.8.1 schematically depicts a buffer adjoining the Dry Fork <br />channel. The operator requests approval to extract up to 50~ of the <br />in-place coal beneath this buffer zone. This same scheme was presented <br />