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Please prepare a request for variance from approximate original contour <br />reclamation requirements for the mine bench/access road portion of the mine <br />area, in accordance with the provisions of 2.06.5 and 4.27.4, for inclusion in <br />the revision application. The specific area for which the variance is <br />requested should be delineated on the Postmine Topographic Map. Each of <br />the specific provisions of 2.06.5 and 4.27.4 will need to be addressed. We <br />would request that you contact us if you believe that the proposed <br />topography can be approved under provisions other than 2.06.5 and 4.27.4, <br />so that such approaches can be discussed and evaluated prior to expenditure <br />of time and resources in development of detailed plans. <br />14. All highwalls must be eliminated, pursuant to 4.14.1(2)(a) and 4.14.2(1)(6), <br />unless a variance is approved in accordance with 4.14.1(2)(f) or (g). The <br />reclamation plan for the portal bench area appears to achieve elimination of <br />highwalls, but additional detail and clarification is requested. The extent of <br />existing highwalls will need to be clearly delineated on an appropriate map, in <br />order to avoid potential future conflict regarding whether certain cut slopes or <br />rock faces in the vicinity of the mine bench area are or are not highwalls. Please <br />provide a 1" = 100' scale topographic map of the mine bench area existing <br />topography, with 2'contour intervals, on which the crest and perimeters of <br />the highwalls referenced in the revision narrative are clearly delineated. <br />15. Labels associated with the Cross-Section K-K' diagram on amended Exhibit 26 <br />appear to be erroneous and/or are somewhat confusing, and clarification is <br />requested. The slope labeled "Existing Ground Surface" (red line), is clearly not <br />the existing ground surface. Rather, it appears to represent the currently approved <br />postmining slope (at least along the upper section), and should be relabeled as <br />"2003 approved ground surface", or otherwise accurately labeled. On the same <br />section, the green line labeled "Final Ground Surface" should perhaps be labeled <br />"PR-3 Proposed Final Ground Surface", for clarity. Certain information that is <br />depicted on Existing Section K-K' is not depicted on the PR-3 Section, including <br />the existing ground surface, highwall crest location, and Diversion Ditch A-A' <br />location. This information should be included on the PR-3 diagram (note that the <br />actual elevation of the diversion ditch appears to be higher on the slope than <br />depicted on the current version of Section K-K'). Note also, that, if the red line <br />does depict the "2003 approved ground surface", the slope should continue at <br />significant grade throughout the section, rather than leveling off at elevation of <br />approximately 4838'. Please review these concerns and provide a properly <br />amended Sectiion K-K'. <br />16. The application does not include a stability analysis as required by various <br />applicable sections of 4.03.2(3)(3), 4.14, and 4.27.4, to demonstrate that the <br />proposed 2:1 backfil] slopes will have a minimum static safety factor of 1.3. <br />Please include in the application a demonstration by a qualified registered <br />professional engineer that the proposed fill slopes associated with the portal <br />backfill and access road will have a minimum static safety factor of 1.3. <br />5 <br />