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Any refuse generated from mining and processing of coal from the Wolf Creek Reserve will utilize <br />capacity previously identified for the Sage Creek life -of -mine operations. If additional refuse <br />capacity is needed in the future to compensate for reallocation of this incremental capacity, TC <br />will review options for either an additional expansion of the existing CRDA or a separate CRDA <br />location, and prepare and submit the necessary design and permitting documents for CDRMS <br />review and approval. Given that the existing CRDA is designed and permitted to support <br />approximately 25 years of operations, and that any requirement for additional refuse capacity <br />would not occur for 15 to 20 years, this approuch is both reasonable and viable. The relevant <br />PAP text has been revised to include a referance to use a portion of the designed capacity of the <br />CRDA for the Wolf Creek operations, and copies of the revised text accompany these responses. <br />Division Response - It is noted that the Division is currently reviewing a Permit Revision (PR -1) <br />for the Peabody Sage Creek Mine to modify perations from continous mining to longwall mining. <br />Based on the PR -1 application the processing facilities at the Foidel Creek Mine will be utilized <br />for the Peabody Sage Creek coal and subsequent processing waste generated from the Peabody <br />Sage Creek Mining operations. Due to the fact that TR -83 is an application to ramp down to the <br />Wolf Creek Seam and develop gate roads, the Division determines that the TC response is <br />adequate. <br />Division's initial comment - The submitted application form for TR -83 identifies 1600 acres as a <br />proposed change in affected area and proposed page 2.05 -11.2 states that there will be no <br />change in affected area. Due to the fact that the area of the proposed Wolf Creek mining has <br />previously been affected, the gate roads and bleeder entries will not be identified as affected <br />again. However, based on proposed Map 23 the area of the ramp down has not been affected. <br />Please identify the number of new affected acres, only those acres not previously mined. <br />TC Response - The figure of 1,600 acres reflects the area that would be re- affected by mining at <br />such time as actual full -scale mining and the associated subsidence occur. The Division's <br />approach in not showing this re- affected area as incremental disturbance is reasonable, and in <br />fact, this area would not eb impacted by the proposed initial development activities because the <br />proposed development activities wold not result in subsidence. Similarly, the ramp -down area <br />would not result in any surface disturbance or subsidence, since it will be driven within the Mine <br />from the existing Wadge Seam workings down to the Wolf Creek Seam and would incorporate <br />supplemental support so that there would be no collapse or subsidence. Given these <br />considerations, TC has corrected the application form to reflect no change in affected area, a <br />copy of which accompanies these responses. <br />Division Comment - This response is adequate. <br />-'coda <br />1313Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 <br />I <br />1876 <br />