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S <br />• <br />• <br />Anthony J. Waldron December 1, 1995 <br />Re: 1995 Annual Reclamation Report <br />slope, the factor of safety of the slope will decrease. <br />Appendix J presents the slope stability study for the <br />reclaimed area. The factor of safety of the reclaimed <br />area is acceptable but not excessive. Somerset must <br />resist any revision to the reclamation plan that will <br />reduce the stability of the reclaimed slope." <br />The draft was discussed during a Division on-site <br />inspection on March 17. After the discussion, Somerset <br />agreed to remove the upper bench from the final <br />topography, and recheck the stability analysis as <br />requested by the DMG letter. <br />The responses were submitted on May 31. The stability <br />analysis produced a factor of safety of 1.0437 to <br />1.1026 for the original contours and 1.0955 to 1.2547 <br />for the revised final contours. The original contours <br />and the revised final contours do not meet the Division <br />requirement for a minimum static safety factor of 1.3. <br />The safety factor for the revised final contours is a <br />result of a slight overall decrease in slope and a <br />lower elevation of the roadway location, as compared to <br />the original contours. The revised final contours are <br />essentially approximate original contours. <br />On July 12, <br />including the <br />Creek site. <br />revised plan <br />increased work <br />estimate to <br />schedule to fi <br />four representatives of the Division, <br />Division Director, inspected the Bear <br />The previously approved plan and the <br />were explained and discussed. The <br />requirements were pointed out. The time <br />complete the work, and the required <br />Dish before winter, was emphasized. <br />Somerset and DMG both recognized the difficulty of <br />completing the proposed reclamation work at the Bear <br />Creek site. A revised page was submitted on July 19 to <br />incorporate this concern into the permit, The revised <br />page stated the DMG and the Operator will jointly <br />determine when the regrading work is complete with <br />consideration given to safety of the workers and the <br />degree of difficulty to complete the remaining grading <br />work. <br />Technical Revision No. 23, Bear Canyon Reclamation <br />Amendment, was proposed for approval by the Division on <br />July 26, and published for the ten-day public comment <br />period on August 2. During the public comment period, <br />on August 8, Bear Coal Company objected to the proposed <br />decision and requested a Board Hearing. "Bear Coal <br />6 <br />