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Coal and coaly material will be scraped from the work bench area and placed against the coal outcrop and sealed adits. A portion of the material in the work area will then be brought up to cover the outcrop and will be graded to contours approximating those in existence prior to the startup of mining operations (See Figure 3.1-1). The maximum overall slope within the work area will be approximately lv:3h in the upper portion of the area along the natural cliff area. To summarize the above discussion and excerpts, the Division's Findings indicate that the portal area will not be returned to approximate original contour, and that a steep slope AoC variance will be granted; whereas the permit application package text states that the portal area will be returned to approximate original contour, and makes no mention of a steep slope variance. As a part of this mid-term review process, this conflict between the permit application package and the Findings of Compliance will need to be resolved. To that end, we have the following comments and questions: 1. Figure 1.1-2 and 2.2-1 referenced in the permit application text as existing and pre-mining contours could not be located in the Division's copy of the application. These exhibits or equivalents, along with appropriate cross sections as provided in Figure 3.1-1 "Reclamation Plan Map", will need to be provided to allow for a thorough comparison of pre-mining and post-mining topography, and evaluation of approximate original contour and highwall elimination plans. The cross sections depicted as A-A' and B-B' on Figure 3.1-1 should be provided for "existing" and "pre-mining" topography, in addition to the sections on Figure 3.1- 1 which depict "proposed mine bench" and "reclaimed mine bench" slopes. A map scale of 1"=100', with 5' contour intervals is requested. 2. Although we could not locate a pre-mine topography map, apparent original topography was inferred from existing topography as depicted on Exhibit 2.2-4, and compared with the postmine topography of Figure 3.1-1. A preliminary pre-mine/post-mine comparison based on cross section A-A' appears to indicate that the southern cut slope created by the proposed mine bench expansion would be only partially backfilled, leaving an exposed highwall remnant 40 to 50 feet high, at a grade of approximately 65$. In general, the reclaimed configuration would result in a steeper hillslope crest (the highwall remnant), but backfill slopes would be significantly shallower than pre-mining slopes, and the valley bottom would be elevated by the fill. The upper hillslope landform would shift from convex prior to mining to slightly concave following reclamation. Evidently, the Division made the determination that the proposed reclamation configuration did not represent approximate original