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Ylichael G. Altavilla D R/q FT Seneca Coal Company Page 5 April 23, 1999 15. Rule 4.03. l (2) requires that haul roads be located on ridges or on the most stable available slopes to minimize erosion. It appears that a portion of proposed Haul Road "B" Extension would be located within surficial landslide deposits. The Division has reviewed SCC's statement relating to "Potentially Unstable and Active Landslide Areas" on revised page 9 of Tab 12. Exhibit 6-l, "Site Specific Geology" and PR- Ol Exhibit l2-l, "Operations Plan" were also reviewed and compared to identify landslide areas that may be in clbse proximity to proposed facilities. The original permit discussion stated that the potentially unstable and active landslide areas would be field verified during the 1993 field season. They were verified by SCC, and the results were reviewed and accepted by the Division. The application also states; "Since the majority of these unstable azeas will not be affected until 1999 or later, Seneca will continue to monitor those areas which have been field verified. The mining plan may be revised to minimize the disturbance in these potentially unstable azeas based on the outcome of the field surveys and the mining operations which will occur neaz these areas." Comparison of Exhibits 6-1 and 12-1 determined that the mining projected to occur in 1995- 1999 should have encountered several azeas designated as potentially unstable. However, it appears those azeas projected for extraction in 2000-2004 will encounter more numerous and extensive potentially unstable land surface. In anticipation of this pending disturbance of potentially unstable land masses, SCC should provide the Division the results of its survey observations and operational experience since 1993. SCC should summarize its experience in mining potentially unstable areas mined to date, based upon its monitoring and verification conducted since 1993. Specific emphasis should be focused upon: (1) the relative success of traditional mining, regrading and reclamation methods within these areas; and (2) any non- traditional or innovative methodologies implemented within these potentially unstable azeas. The observational approach was appropriate in 1993. However, having compiled several years of operational observation within the permit area, SCC should now document the preliminary results of its observational experience within the permit record. Please update the permit application package (PAP) accordingly, and consider all available options for locating proposed roads so that they are placed on stable surface areas. 4.06.3 Topsoil Storaee 16. Rule 4.06.3(2) requires that stockpiled materials be selectively placed on a stable surface area within the permit area. Of particular concern are proposed topsoil piles N and Q, which would be located within or very close to active landslide areas. Please consider all viable options for locating proposed topsoil piles [o ensure that they are placed on stable surface