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Mr. Roy Kazo <br />Seneca Coal Company <br />7/14/2004 <br />Page 3 <br />"In certain areas, highwall mining and retention of mine haul roads will preclude <br />rough backfilling and grading within 180 days of final coal removal". <br />1 i. Please see the Division's response to item 1 c above. <br />lj. Response accepted. <br />lk. Response accepted. <br />11. The area designated 2005 HW Miner on the eastern perimeter of the Yoast South <br />azea also extends to within close proximity of the permit boundary. Please adjust <br />the highwall mining limit at this location (Exhibit 12-1) to account for potential <br />subsidence and to ensure any subsidence effects will remain within the permit <br />boundary. Engineering design analyses specifically addressing subsidence effects <br />should be submitted to the Division. <br />1 m. Response accepted. <br />ln. Response accepted. <br />lo. Response accepted. <br />Ip. Please incorporate the variance azeas designation into the Legend on Exhibit 19- <br />1 A. <br />lq. Response accepted. <br />1 r. The timeframe for post mine channel construction is generally acceptable based <br />on the backfilling and grading schedule. The Division is concerned that several of <br />the post-mine channels including YPM-1, 3, 6, and 7 are proposed to cross haul <br />road locations. There aze no drainage control structures indicated at these <br />crossings. How will the post-mine channels be constructed so that erosion is <br />minimized at haul road crossings? Diversions of overland flow shall be designed, <br />located, constructed, maintained, and used to minimize adverse impacts to the <br />hydrologic balance, and to be stable. To ensure compliance, please provide a <br />culvert design or other acceptable drainage control/diversion design for these haul <br />road crossings. It appears that certain sections of the post mine channels will not <br />be constructed until after the haul road(s) aze removed. These disturbed azeas that <br />will remain un-graded (particularly requested vaziance areas) will be highly <br />susceptible to erosion. Please provide the Division with an erosion and sediment <br />control plan for disturbed/un-graded azeas for the interim period prior to final <br />grading, topsoil redistribution, seeding, and channel construction. <br />ls. Response accepted. <br />