2014-08-19_REVISION - C1996083

• Permit No: C1996083
• IBM Index Class Name: Revision
• Doc Date: 8/19/2014
• Doc Name: Second Adequacy Review Letter
• From: DRMS
• To: Bowie Resources, LLC
• Type & Sequence: PR14
• Email Name: SLB
• Media Type: D
• Archive: No

William A. Bear
Page 4of8
August 19, 2014
19. Issue resolved; the Division will place a stipulation on approval of PR -14 stating that no
surface disturbance can occur on any Spruce Stomp lease land prior to submittal and
approval of baseline vegetation data.
20. BRL has drilled more than 75 gob vent boreholes to support its current mining operations
(Drill Holes — Original Ground Slope Information, Permit page 2.05 -44 & 45) and the permit
states that "three or more gob vent boreholes are required over each longwall panel" (page
2.05 -43). While no disturbance in the Spruce Stomp lease area is being proposed at this
time, the Division anticipates that more gob vent boreholes will be needed in future
operations within the Spruce Stomp expansion area. Please take note, that vegetation data
that meet the standards of Rule 2.04.10 will need to be submitted to and approved before
future disturbances can be approved. As noted in Item 19, above, the Division will place a
stipulation on the approval of PR -14 to require baseline vegetation data prior to any
disturbance in the Spruce Stomp lease area.
21. Issue resolved; no response to the Division's comment was required from BRL.
Rule 2.04.11— Fish and Wildlife Resources Information
22. Issue resolved; BRL provided the requested discussion as a new Exhibit in Tab 23 of Volume
1116.
23. The Division anticipates that future operations will involve disturbances in the Spruce
Stomp expansion area (see Item 20, above). Please take note that a
threatened /endangered species survey or block clearance will need to be submitted and
approved before any future disturbances can be approved. As such, a stipulation will be
placed on the approval of PR -14 prohibiting any surface disturbance in the Spruce Stomp
lease area until the required survey or clearance has been submitted to and approved by
the Division.
Rule 2.05.3 —Operation Plan
24. Issue resolved; no response to the Division's comment was required from BRL.
25. BRL did not provide a response to this issue: Please provide information on BRL's proposed
plans for disposal of the coal processing waste, as required by Rule 2.05.3(8), that will be
generated as a result of mining the reserves in the PR -14 expansion area.
Rule 2.05.6 — Mitigation of the Impacts of Mining Operations
Rule 2.05.6(3) — Protection of the Hydrological Balance
26. Issue resolved; no response to the Division's comment was required from BRL.
27. The Division asked BRL to update Maps 09, 15 -1, 15 -2, 15 -3, and 15 -4 to include the
designated stream buffer zones required by Rule 4.05.18 for all perennial streams and
intermittent streams or ephemeral streams draining an area greater than one square mile