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-1:. <br />Mr. Dan Mathews <br />June 13, 2008 <br />Page 2 <br />5. On page 1 of revised Attachment 13-12, SCC states that Pond 012A would be used "...if Pond <br />012 continues to lose capacity from upslope instability previously experienced adjacent to the <br />pond area." "If the area stabilizes then Pond 012A will not be constructed." It does not appear <br />that the area is going to stabilize given recent significant slide activity immediately adjacent to <br />Pond 012. The Division believes that building Pond 012A is warranted. SCC has presented <br />two options with this revision; Postmine Topography Option 1 (Pond 012 only) and Option 2 <br />(Pond 012 and 012A in series). Since the slope above Pond 012 remains unstable the Division <br />recommends Option 2. Please revise all text, channel designs and appropriate maps to indicate <br />Option 2 only. As part of Option 2, the Division believes that there may be some advantage to <br />reducing the dimension of Pond 012 to allow for lengthening the toe of the unstable slope <br />above and to the east of the pond, and to provide more room and soil material for grading and <br />stabilization to the east of Pond 012. The Division asks that SCC give this some consideration <br />when developing the slide remediation plan required in Abatement Step 2 of NOV CV-2008- <br />001. <br />6. Hydrologic input parameters including original approved curve numbers (Table 13-1) for <br />Ponds 010 and 011 were initially given in Tab 13 Facilities section. Attachment 13-12 was <br />subsequently prepared for the Yoast South area (Ponds 012, 013, and 014) and contained a <br />second modified curve number table. With TR-37 Attachment 13-12 was significantly <br />modified and Table 13-12.1 Yoast Mine Curve Numbers was substantially expanded. We now <br />have two lengthy curve number tables in two different sections of the permit. To avoid <br />confusion, it would be helpful to have both curve number tables be consistent with each other, <br />or refer the reader to just one location in the permit for approved curve numbers. Please update <br />the appropriate sections of the permit document accordingly. <br />7. A couple of errors were noted on Figure 13-12.3. Channel YPM-6-2A was not included in the <br />figure. Under YPM-18 the slope is given as 11-313%. Please make the necessary corrections <br />to Figure 13-12.3. <br />On new Exhibit 13-12.1A and revised Exhibit 20-2, Postmine Channel YPM-3-2A is missing. <br />Please include this channel on the exhibit. <br />9. The watershed boundary designations have become confusing and difficult to correlate between <br />the channel and pond designs and the exhibits that show the watershed boundaries and <br />designations. For example, it appears that the designations shown on Exhibit 13-12.1 no longer <br />correlate with the Watershed Identifications and the hydrologic input parameters for the <br />postmine channel and pond design SEDCAD runs for the Yoast South area. It is also appears <br />that Exhibit 13-413 needs to be updated with the current watershed condition as of September <br />2007 and with new Channel YPM-22. If appropriate, remove Exhibits 13-12.1 and 13-413 and <br />replace them with a single map showing the revised watershed designations. Alternatively, the <br />appropriate watershed designations could be added to the new Exhibit 13-12.1A. <br />10. Please revise Appendix 13-12.3 with an updated channel design(s) for the YPM-4, 4-1, 4-2, <br />YPM-17 and Diversion 13A system of channels that flow into Pond 013. There were no <br />previous existing designs for Diversion 13A and it appears that the existing channel