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Mr. Michael S. Savage June 26, 1996 -Incomplete App. Page 3 8) Revised permit text paragraphs 4 of Page 5-11 and 2 of Page 5-13, addressing the alteration of the Carfion Junction Canyon drainage way, was not provided. With regard to Regulation 2.05.3(3)(c)(iii), it is immaterial how or when the haul road was approved and constructed in relation to how or when the rock fill was approved and constructed. The fact remains that anactively-used haul road currently exists on a fill that has altered a drainageway. As such, the permit text must be revised to acknowledge this fact and come more fully into compliance with the Regulation. 9) A revised text paragraph, addressing the existence of the three 24-inch culverts on the ground rather than the two approved in the permit, was not provided. ] 0) The revised designs for the surface water diversions above the Carbon Junction Canyon rock fill were not provided. 11) A revised paragraph 3, Page 5-20, removing the statement "the need for a designed underdrain is not applicable," was not provided. 12) The slope stability analysis of the rechunation of the North Pit was not provided. 13) A discussion of how OII will prevent creep or slippage of the rephtced soil materials in the North Pit was not provided. The Division is concerned that using hay bales as anchors may not be a prudent long-term solution, given the propensity of hay bales to deteriorate over time. This discussion is important in that if the replaced soils should begin to creep, small scarps could form in the upper reaches of the reclamation, potentially necessitating a redisturbance of the reclamation by vehicles for the purposes of repairing the scarps. In addition, the Regulations require topsoil and other materials to be redistributed in a manner that achieves, among other things, stability.' Further, should creep become significant, the conditions under which the required 1.3 static safety factor for slope stability was obtained could change to the degree that the 1.3 value would be lessened. The time to address the potential for soil creep, and any contingency plans for its control should it occur, is before construction of the slope. Once creep begins to occur, it would seem extremely difficult to stop without extensive efforts. The Division realizes that it may have previously approved the North Pit reclamation plans without this discussion. However, the Division has statutory and regulatory authority at both State and Federal levels to conduct Mid-Term Reviews and require revisions to permits during the term of those permits. Discussing the issue of creep now, rather than waiting until after problems occur, could save OEI significant financial resources in the future. 14) A revised Map 5-5, identifying only the two vegetation communities proposed for post- mining use, was not provided. IS) A revised permit Page 5-19, pertaining to topsoil replacement depths, was not provided.