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<br />-5- <br />b. During•the review of the soil resource and initial 'waste rock pile <br />sections it was not discussed where material was to be obtained to cover <br />the initial waste rock pile. The topsoil section of the application <br />should be revised to discuss the source of cover material to be used at <br />the initial waste rock site. <br />5. Vegetation <br />a. The reclamation plan is included in the application in Section <br />4.5.7. The "U.S. Steel Lease Laydown Area" is included under this <br />section. The laydown area will nave to meet the same success criteria <br />as for the adjacent mine facilities area, as is explained in the <br />application. <br />In accordance with Rule 4.15.5 tot. Gunnison will need to have an <br />approved grazing plan prior to any grazing activities within the permit <br />area. <br />No responses are required under this section unless grazing is proposed. <br />6. Coal Handling Facilities <br />a. Coal has been noted to fall at certain points on the conveyor, <br />particularly at conveyor bents (in particular, the bent at the <br />intersection of the mine access road at station 13+00). This coal <br />presents some concerns with regard to reclamation, siltation, and dust <br />problems. The problems may become significant given the life of mine is <br />at least 40 years. The operator should discuss the measures used to <br />minimize coal dropping from the conveyor, discuss reclamation procedures <br />(coal removal) around these bents, and formulate methods to contain coal <br />under the conveyor. <br />7. Underground Development Waste <br />a. Stipulation No. 14 (MLR - 34, OSM -31) requireo Mt. Gunnison to <br />complete the stability evaluation and designs for the upper waste rock <br />site prior to construction. Subsequently, the proposal to construct the <br />site was withdrawn. In a letter dated January 13, 1982 from Tom Gillis <br />to Paige Seville the Division indicated this stipulation was resolved. <br />However, it was also stated "in order for the Division to be able to <br />approve the waste pile during the future permit term ... Arco Coal must <br />follow the recommendations contained within the preliminary stability <br />evaluation" and "it is essential that the monitoring system as <br />recommended by Geo-Hydro Consulting, Inc., be installed prior to the <br />driving of the entries beneath the pile". <br />Contacts with the operator and field inspections reveal that the <br />monitoring system has not peen installed, and entries nave already peen <br />driven. Since the waste pile proposal has been withdrawn this issue <br />does not put the operator out of compliance. However, this issue nay be <br />a significant factor in the future if Mt. Gunnison decides to permit the <br />upper waste rock site. <br />