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Page 3 of 3 <br />21. Within the subsidence portion of Section 2.05.6 of the PAP, there is no discussion of potential impacts of subsidence <br />on renewable resource lands. Please explain this, especially in the context of potential groundwater recharge. <br />22. On pages 2.05.6 -55 and 2.05.6 -56 of the PAP, the list of structures that could be impacted by subsidence does not <br />include the Corley Company Well. This text needs to be edited to include this well. EFCI also needs to confirm that <br />no other wells are within the areal extent of predicted subsidence. Also, text in Section 2.05.6 should be revised to <br />include a discussion of potential damage to this well (or these wells) and mitigation measures, including <br />compensation if applicable, to address any damage caused by subsidence. <br />23. Regarding Rule 4 sections of the PAP, introductory text describing the current status of the mine and loadout should <br />be added to applicable sections. These include any sections in which coal mining operations are described as ongoing <br />and any sections that contain outdated information (e.g., discussion on modifications to the Magpie Creek diversion, <br />discussion on ponds). <br />24. Page 4.05.6 of the PAP does not flow with the previous page and needs to be revised. <br />25. The PAP discusses buffer zones (page 4.05 -29) but references the old version of Rule 4.05.18. EFCI needs to address <br />buffer zones in light of the current rules. EFCI needs to look at Newlin, Magpie, and possibly other creeks at the mine <br />site. At the loadout, EFCI needs to look at the need for a buffer zone for Oak Creek. <br />To remain in compliance with Division rules, please address these items, with permit revisions if necessary. If you have <br />any questions feel free to contact me at (303) 866 -3567, extension 8113. <br />Sincerely, <br />Robert Zuber, P.E. <br />Environmental Protection Specialist <br />