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Mr. David Beverlin - 3 - January 30, 1990 12. In 1984 and 1986 the Edna Strip Mine experienced major land slides As a result of these incidents P8M retained a consultant, Water, Waste and Land, Inc. (WWBL) to study stability characteristics at the property. In Section 3.3 of the report dated December 16, 1986, WW&L recommended a monitoring plan for the Moffat area. Due to past mass movements at the mine and the proximity of the perennial Trout Creek, MLRD believes it is necessary to implement WWBL's recommendations for monitoring. Please address implementation of the recommendations or provide a technical discussion demonstrating why conditions are such that this monitoring is no longer necessary. ~. Proposed Section 3.4.2.1 states that "grading will leave approximately 100 feet of undisturbed ground between Trout Creek and the active grading ~lL area." Rule 4.05.18(1) states "no land within 100 feet shall be disturbed." P&M should modify their statement to reflect that the 100 foot buffer zone will remain intact. 14. A revised Table of Contents must be submitted to reflect all chances, additional exhibits and appendices. 15. During the review we generated the following comments concerning your exhibits: A. EXHIBIT 1.0-1 needs a le_aend to differentiate between pit and permit area lines. B. EXHIBITS 1.0-1 and 3.3-5 are intended to show the same information. However, 3.3-5 indicates that northernmost lines are the northern extension of the pits and permit boundary. A legend would help distinguish between these boundary. C. EXHIBIT 3.1-3 needs to be revised to reflect information shown on Exhibits 3.3-5 and 4.3-1. The affected area is defined as all areas of disturbance. An affected area fora year should include the pit, the zone of regrading and the area of topsoil salvage. D. RULE 2.10.3(2) requires that all maps, plans and cross sections shall be certified by a qualified professional engineer. This should include an imprint of the professional engineer's stamp, signature, and a brief statement that the work was completed employing proper practices under the direction of the engineer and are true and correct to the best of the engineer's knowledge. One copy of the exhibits must bear this original certification. The second and third copies may be reproductions of the original. E. EXHIBIT 3.7-1 should have a legend specifying permit and property lines. Rule 2.10.1(3) requires that the permit boundary be shown on all maps.. CEXNIBIT 4.3-has dashed lines showing the limits of topsoil rem vo al by mining year and a stippled area reflecting non-salvaged ~~ 5 topsoil. It is uncertain if the outer border of these combined In areas equal the affected area boundary. According to Rules 1.04(7) ~et ~ and 1.04(36), the affected area should be eo.ual to the disturbed area.