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West Elk Mine, PR-07 Response to Adequacy Comments Response to Question #71. MCC has responded to the Division adequacy concern addressing slope stability of the operational and reclaimed configurations for the SGFA by submitting copies of geotechnical reconnaissance studies of the SGFA performed by various consultants between September of 1993 and July of 1996. While their submittal provides additional valuable geotechnical information it does not resolve the Division's earlier concern. Basis for, and Character of, the Division's Concern In it's original geotechnical adequacy comments the Division stated; "The potential for disruption of the proposed new PR-07 surface facilities at the West Elk mine by landsliding represents a significant potential for damage to the environment and compromise of the public health and safety. If the various haul/access roads, light use roads, electric substations, surface drainage facilities, or shafts and associated surface facilities are disrupted by newly initiated or rejuvenated landsliding, the public and the environment could be subjected to risk. As such this potential must be adequately addressed within the permit application. Cuts and fills on landslide prone materials, such as those proposed to accommodate the proposed PR-07 surface facilities at the West Elk mine, can be particularly problematic." "The Division is particularly concerned with the eventual reclamation of the proposed PR-07 facilities. Cuts and embankments proposed to be retained as part of the reclaimed configuration will have to be analyzed to demonstrate their structural and geomorphic stability. The Division can approve PR-07 only after acceptable design detail, including construction methods, specifications, and stability analyses, have been completed to demonstrate the stability of both the operational and reclaimed configurations for all the proposed facilities." General Character of MCC's Geotechnical Response to Comment #71 MCC, Golder Associates (MCC's design and geotechnical consultant), and the Division met in January to discuss the Division's adequacy comments. During that meeting MCC and Golder presented their opinion that the slope stability challenges within Sylvester Gulch were less severe than the Division feared and could be managed by appropriate engineering accommodation. MCC has now submitted additional information to support that opinion. They have included a selection of earlier geotechnical investigations of Sylvester Gulch, performed by a selection of geotechnical and geological consultants under their employ, most familiar to the Division, for the Division's information. Apparently some of these materials, not submitted in duplicate, are not intended by MCC to be made a portion of the record. Also in response to the Division's suggestion, MCC has submitted one full-size copy of its Request for Proposal