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Dan Mathews -2- June 27, 2007 <br />2. DRMS: On amended page 147 (Rev. 7/06), the second sentence of the <br />second paragraph includes the phrase "and a portion of the office". This <br />language refers to a version of the plan that was subsequently changed; the <br />plan to be approved specifies complete demolition of the office structure on <br />the mine bench. Please delete the referenced phrase. <br />SCC: Amended page 14-7 is enclosed. <br />3. DRMS: The detailed area description and reference to Rule 4.14.10(3), in <br />the third paragraph on page 14-16 (Rev. 4/25/07) would appear to be <br />unnecessary, and could possibly cause confusion, since the location is <br />included within a designated "Active Area" that does not require seeding. <br />Please delete the third paragraph on page 1416 and amend the second <br />paragraph to read as follows: <br />Areas of the commercial postmining land use designated as <br />"Active Area" on Exhibit 6C-A, will not be seeded. Also, most <br />of the area described as steep rock face on Figure 14-14 will <br />not be revegetated due to the very steep gradient and nature <br />of the material along the slope. <br />SCC: Amended page 14-16 is enclosed. Also included is amended <br />page A14-5-33. <br />4. DRMS: On page A149-1 (02/07), the introductory paragraph under <br />"Watershed Analysis -Rule 2.06.5(2)(d)" contains erroneous wording, <br />although the substantive demonstrations included in the analysis are correct. <br />The "or" preceding section (ii) should be "and" to conform with the Rule, and <br />to be consistent with the demonstrations that follow. Please amend the text <br />as appropriate. <br />SCC: Amended page A14-9-1 is enclosed. <br />5. DRMS: On page 14-7 (Rev.7/06), there is reference to near vertical rock <br />faces in the mine bench area that are not considered highwalls and will not <br />be eliminated. Stability analysis provided in Appendix 14-8 demonstrates that <br />proposed highwall backfill slopes and road fill will meet the 1.3 safety factor <br />requirement. However, no stability analysis has been submitted to <br />demonstrate that the near vertical rock faces in the mine bench area will meet <br />the 1.3 safety factor. The Division has concluded that the requirements of <br />Rule 4.27.3 apply to the steep rock faces that were excavated in association <br />with construction of the mine bench and associated facilities. As such, a <br />geotechnical analysis demonstrating that the steep rock faces meet the 1.3 <br />safety factor pursuant to Rule 4.27.3(3) will be required, unless an alternative <br />demonstration of compliance pursuant to Rule 4.27.3(8) can be made. <br />Please address the concern and provide an appropriate analysis of the <br />steep rock faces in the portal bench area, to demonstrate compliance <br />with 4.27.3(3) or 4.27.3(8). <br />