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expensive, and is probably the only feasible alternative in any case, as the <br /> underground workings have become inaccessible. <br /> MLRD will, 1 believe, .agree to this change. <br /> 2. Construction of Seals. <br /> The present reclamation plan calls for construction of impervious seals at all <br /> other openings. <br /> The plan filed with WSHA calls for installation of drains to prevent Impoundments <br /> of water at several locations, and otherwise specifies only that the material used <br /> for portal sealing will be incombustible. but not impervious. Impervious seals <br /> would, of course, be considerably more expensive, although the bond amount <br /> probably did not consider the additional cost of impervious seals. <br /> I believe the Division will agree to this proposal as well. <br /> 3. Number of openings. <br /> The reclamation plan, when written many years ago, was somewhat incomplete <br /> in that the total number of openings, including ventilation openings at sites which <br /> are difficult to access, had not been inventoried. The most current estimate of <br /> the number of openings to be closed, or at least examined to determine that they <br /> have been closed properly, is more than 50. <br /> MLRD, like MSHA, will require the closure of all openings. Reduction of costs <br /> for sealing the tunnel will help to offset the added costs for sealing the greater <br /> number of portals. <br /> Reclamatlon of Benches <br /> The five portal benches were created long before passage of the Surface Mining <br /> Reclamation Act (SMCRA) and the state version, which call for restoration to <br /> approximate original contours and backfilling of all highwalls. <br /> This could be a major problam for us as complete backfilling of the highwalls would <br /> require vast amounts of soil and rock material which is simply not available. <br /> Wo presented the Division some cross-sections for implementing the current plan, <br /> which calls for constructing a buttress along the base of the cut in the hillside from the <br /> foundations of the buildings, and available material from the fill at the outside edge of <br /> the bench. Under this plan we would not attempt to fill in the entire highwall, nor to <br /> restore the bench areas to pre-mining contours. <br /> 2 <br />