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<br />)~ <br />Memo to Jim Burnell <br />West Elk Mine, TR-84 Supplemental Submittal <br />page 2 <br />Section 7.0 of Barr Engineering's report and Christine Johnston's cover letter both <br />contain references to a five year observational approach to verifying stabilization of <br />the landslide mass. Barr Engineering recommends that pore pressure and <br />movement monitoring be continued "until a level of confidence has been reached..." <br />"However, since this time period cannot be determined at this time, future <br />monitoring should continue for a period of at least five years, through several <br />climatic conditions, and the probability of landslide outcomes should be revised on <br />an annual basis, after the spring runoff and the existing reclamation plan should be <br />adjusted accordingly." Ms. Johnston states in her cover letter; "Information has <br />been added to the report regarding the monitoring program that will be conducted <br />over the long-term, as well as a commitment to reevaluate the reclamation plan <br />after at least five years of data have been collected." <br />In my opinion Barr Engineering's recommended observational monitoring and <br />reevaluation methodology is an acceptable approach in this emergency remediation <br />scenario. In order to avoid any future misunderstanding, however, I recommend <br />that the Division request that MCC submit a clearly worded letter specifically <br />committing itself to complying with Barr Engineering's recommendations. Further,•I <br />recommend that you impose specific annual dates, such as July 15th, for the <br />annual submittal of the updated monitoring data and detailed evaluative report. The <br />purpose of this annual report shall be to update the report submitted and revised in <br />TR-84, including an evaluation of the relative change in FOS accomplished during <br />the past year and cumulatively since the commencement of remedial treatment of <br />the facility area landslide. <br />attachment: <br />cc: Larry Routten <br />doc: M:\COAL\JAP\MTG84SUP.WPD <br />JP/jp <br />