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32. Yellow Sweetclover <br />Yellow sweetclover is referred to on page 4.15-1 as being included in the <br />permanent seed mix. Examination of Table 10 does not show this to be <br />listed because the Division had requested that it be deleted from the <br />seed mix. Please adjust the text on page 4.15-1 to reflect the currently <br />approved seed mix. <br />Topsoil <br />33. Disturbed Acreage <br />The Division has recently estimated the amount of disturbance associated <br />with the Bear No. 3 area. Using aerial photos, the amount of disturbance <br />was estimated at 10.32 acres. Using Bear Coal Company's Mine Facilities <br />map (Map 10 ), an estimate of 8.32 acres was obtained using a digitizer. <br />Both estimates exceed the predicted five acres of disturbance (see pages <br />2.04-43, 4.15-2, 4.15-3 and Map 1 of Exhibit 23). Bear Coal has <br />committed to redistributing six (6) inches of topsoil over the entire <br />disturbed Mine No. 3 area. This would require 8325 cubic yards (10.32 <br />acres) or 6711 cubic yards (8.32 acres) depending on which estimate is <br />determined to be correct. The Division, through survey work this summer, <br />has estimated the Bear Mine No. 3 topsoil stockpile to contain 3129 cubic <br />yards of material. Exhibit 23 (which should be referenced on page <br />2.05-24R) states that 3600 cubic yards have been salvaged. Both of these <br />latter amounts are not enough to meet the 6 inch commitment if the <br />disturbance at the site is 8.32 or 10.32 acres. Please clarify this <br />issue as ii is also important with reference to bond calculations. <br />Clarification should include a determination of total disturbed acreage <br />and amount of stockpiled topsoil. <br />Subsidence and Stability <br />34. Reference to Latest Geotechnical Report <br />Page 2.05-59 references the "Geotechnical Report prepared for Bear Coal <br />Company by Rocky Mountain Geotechnical in January 1986..." This section <br />should be revised to reference the additional report prepared in 1989 <br />generated in conjunction with the B seam mine plan submittal. <br />Bond Calculation <br />As noted in the preamble, a review was carried out of the amount of bond that <br />should apply to the Bear permit area. Adequacy issues resulted from this <br />review: 36 through 38 involve clarification of assumptions that the Division <br />had to make in calculating the bond. The final issue identifies that, <br />according to our latest estimate, the Bear mine properties are underbonded. <br />-11- <br />