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The position (east/west coordinates and elevation of the pins should be <br />monitored quarterly for the first year following installation, and annually <br />thereafter. The timing of the monitonng should be planned so that freeze/thaw <br />action does not influence the position of the pins. <br />Should the monitoring indicate that there is movement, the parting might have to <br />be fractured in an attempt to drain the interburden and increase cohesion. <br />P&M should submit a minor revision to the Edna Mine permit to include installation and <br />monitoring of these pins. <br />In addition to Mr. Routten's observations, the above recommendations are based on two more <br />assumptions that need to be verified by P&M. They are: <br />1. At the time of fracture, there was no effluent from the parting that was fractured <br />by P&M to facilitate drainage to the spoil spring. <br />2. Subsurface water from the final Moffat pit will flow to the existing spoil spring <br />since the two are not structurally separate. <br />To verify this assumption, P&M should compile information from drill hole logs <br />and/or pit surveys to document the dip and strike of the coal. <br />If these assumptions are not valid, P&M needs to provide the Division with accurate information <br />so that P&M and the Division can further contemplate a plan for long term stability of the <br />Moffat area. <br />I have enclosed copies of all memos referenced herein. Should you have any questions or need <br />additional information, please contact me. <br />Sincerely, <br />Susan L Burgmacer <br />Environmental Protection Specialist <br />c: Jim Pendleton <br />Larry Routten <br />Enclosure <br />SLB\1(10295.WP <br />D. Beverlin and B. Gontarck 2 October 2, 1995 <br />