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Mr. Dan Mathews Division of Minerak and Geology Page 5 the potential for reclamation dope failunr .similar to the slide that occurred on the `A" Pit southern Etna! highwall rhpe. Thu request was not addnrred in the TR-49 rubmittaL Bared on Exhibit 20-2A and crow sections on Drawing 20-4.5 of the approved permit, it appearr that segments of several proposed final reclamation slopes in the South Extension area to be reclaimed in 2005 and subsequent years will involve steep slopes arias similar to that which failed in the `A" Pit. C%rr Sections 2, S, 8, 9 and 10 of Drawing 20-4.5 aU appear to incGcde dope segmenu of varying length with gradients in the 40% to SO% range. Please provide a written commitment to amend the South Extension Area backfilling and grading plan as necessary to demonstrate that Snal graded slopes wi// be stable as required by Rule 4.14.1(2)(a) and 4.14.2(1)(b). The commitment will need to specify that a complete technical revision application addressing final reclamation slope stability will be subrnined by January 31, 2005. The commitment should be provided within amended text for msertion into the permit application package. Response: SCC is beginning the process of preparing a new Permit Revision to address the revised mine plan due to the elimination of highwall mining and the remaining surface recoverable reserves. Along with the revised mine plan, SCC will develop a new backfill and grading plan and postmine topography. Our goal is to submit this PR to the Division by January 31, 2005. However, due to the number of variables involved with developing this plan, we will request a meeting with the Division to discuss our approach prior to finalizing and submitting the PR. 4. The Division hat reviewed the Pond 016A capacity verifrartion survey (06/04) and hat determined that the total remaining rapacity of the pond is 13.58 ac ft. This differs from SCC'r calculation of 14.75 ac ft remaining capacity. Thu remaining capacty k almost entirely occupied by water at this time. The Division aka Hated that in the October 8, 2004 application letter, SCC inditater that the initial pool rt 271 ac ft. Bared on the Ar-Built SEDCAD demonrtratian, and the survey nsultr, the Division concrrrr that the pond hat adequate capacity for the 10yr/24hrprecrpitatian event and for redimeret storage without flow through the emergenry spillway. For future capacity vetifcation surveys, p/ease supplement the raw survey data with a p/an drawiug and pond capacity volume calculations. Response: SCC will provide a plan drawing and pond capacity volume calculations with all future pond capacity verification survey submittals. S. In the rover letter, SCC nquerted that the Division accept the Ar-Built >eport anti drawing submitted in March 2004 (IR48) as the `final" Ar-Built for Pond 016A. We do not concur with this approach. Introduction paragraph 1 of current Attachment 13-SI, page 13-SI-1 includes the following statement, winch indicates that the original Ar-Built report it limited to tert~cation of the embankment and rpi/!way (thus pond CapaCtly' Lelifita110fi and other apectr ofpond mnrtruction wen not addressed by the tern nation): This As-Built Report k intended to serve ar canrtrncrion cert~cation for the embankment and spillway only in accordance with Ruler 4.05.6 and 4.05.9. Anew or amended cerd&cation statement will need to be provided for insertion into the permit, which dearly states that the pond m its entirety has been ronstructed and maintained to comply with the approved plan and applicable requirements of Rules 4.05.6 and 4.05.9. A properly rompleted Annual Certification could be used for this purpose, if it a labeled and paginated for insertion into an appropriate permitAttacbmenz