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TWENTYMILE COAL, LLC - FOIDEL CREEK MINE <br />PERMIT REVISION PR15-10 <br />TECHNICAL ADEQUACY RESPONSES <br />TECHNICAL ADEQUACY REVIEW 1 (04/03/15) <br />Table of Contents <br />1. Revised page xii of Volume II -E, Table of Contents appears to be missing Exhibit 54; Wolf Creek Reserve <br />Construction and Development Plans incorporated into the permit with MR282. Please revise this page to <br />list this exhibit. <br />Response: - The Table of Contents has been revised to address this omission. Revised copies of the referenced <br />page accompany these responses for replacement in the PAP. <br />Rule 2.01.6 — Permit Fees <br />2. Revised page 2.01.4 indicates the total disturbed area is approximately 660.4 acres. The Division's <br />records indicate the total disturbed area to date is 734.22 acres. Please clam this discrepancy. <br />Response: - The disturbed area acreage figure has been checked and updated for consistency. Revised copies of <br />the referenced page accompany these responses for replacement in the PAP. <br />Rule 2.03.4 — Identification of Interests <br />3. In accordance with Rule 4.20.2, Twentymile Coal, LLC (TC) will need to distribute by mail the mining <br />schedule to all owners of property and residents within the area above the underground working and <br />adjacent areas. Notification is required at least six months prior to mining beneath the property or <br />residence. Given this requirement, has the surface/subsurface ownership information and maps been <br />reviewed and updated? Please review this information and update it as necessary. <br />Response: - Please see the attached notice and mailing list. This notice was sent to all surface owners and residents <br />within and adjacent to the mine affected area associated with PRI 0. <br />Rule 2.03.6 — Right of Entry Information <br />4. Page 2.05-3 indicates that Twentymile Coal, LLC (TC) is pursuing leasing the Federal coal with a Lease <br />By Modification (LBAI) for the inclusion of the Wolf Creek Seam in the Federal Coal Lease COC -54608. <br />The Division cannot approve a mine plan that includes mining in the Wolf Creek Seam within this area <br />until the LBM has been approved. Should the LBM not be approved by the time all other PR -10 adequacy <br />issues have been resolved, TCC will have to request continued extension of the decision due date until the <br />LBM is approved. <br />Response: - TC recognized and discussed this constraint with the CDRMS at the time the PR10 application was <br />submitted. TC will monitor the status of the pending federal lease modification and coordinate with the CDRMS <br />relative to extension of the decision date for the PR, and submittal of the lease documentation when it becomes <br />available. <br />Rule 2.04.5 — General Description of Hydrolou and Geology <br />5. Revised page 2.04-11, under the WOLF CREEK RESERVE section, indicates "initial development and <br />mining of Panels WC-9RT through SRT would not be affected by pooled water (See MSHA approval for <br />development of Panel 9RT in Exhibit 53) ". Exhibit 53, submitted with PR10, was reviewed. The MSHA <br />letter dated December 31, 2014 in Exhibit 53 states that plans and permits are required that give details <br />