2015-07-21_REVISION - C1982056 (2)

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Twentymile Coal, LLC. Page 12 July 21, 2015 4. Revised Map 23 does not depict panels 12RT to 14RT and panels IRT to 4RT which is references in the text, specifically Exhibit 7K. It may be helpful to depict these panels on Map 23 but indicate or depict on the map that mining is not currently planned for this area with PRIG. a. TC's response: Revisions and updates to the accompanying Map 23WC include delineation and labeling of the referenced longwall panels. In order to clearly delineate the mining activities proposed under PRIO and potential future mining, appropriate shading and labeling has been used. b. Division's response: Item resolved. Page 181.12, indicates the PRIO mine plan is for mining the 5RT to 9RT panels, updated Map 23 shows mining in the 5RT to 9RT panels and the I IRT panel. Map 23 needs to be update to show the sequence of mining to match the text. If TC intends to mine in the I IRT panel, the permit text needs to be updated to indicate this; also the mining sequence depicted on Map 23 needs to include the sequencing of mining this panel. However, it appears a portion of the 1 IRT panel is below the mine pool. The Division cannot approve a mine plan to mine in this area until an adequate water handling plan has been provided. Please revise the mine plan and Map 23 as necessary. a. TC's response: In revising and updating Map 23WC, we reviewed our mining sequence and needs and have removed Panel WC -1 IRT relative to the requested PRIO mining plans and approval. b. Division's response: Item resolved. 6. According to Exhibit 7K, the majority of the movement associated with each longwall will occur when the face is 500 -feet from the rail line and ending when the face is about 1,000 feet past the rail line. According to the proposed revised page 2.05-191.9, TC will begin to monitor subsidence impacts to the railroad when the longwall face is 300 feet from the track. Since subsidence impact is likely to begin when the face is within 500 feet of the track it would seem appropriate to begin monitoring the rail line when mining is within 500 feet of the track. Please revise the monitoring plan to initiate monitoring of the rail line when the longwall face is within 500 feet of the rail line. a. TC's response: Please refer to previous response to Comment 26. b. Division's response: A new revised page 2.05-191.9 was not included in either copy of the technical adequacy review response. Please submit an updated page. 7. According to Exhibit 7K and the revised permit text, flooding/ponding resulting from subsidence will increase Foidel Creeks surface area by 5 acres and Fish Creek surface area a maximum of 70 acres under high water conditions. Please update section 2.06.8(5) of the permit to include a narrative that addresses all of the applicable items required by Rule 2.06.8(5) associated with mining of the WCR under the Fish Creek and Foidel Creek Alluvial Valley Floor. a. TC's response: Section 2.06.8 of the currently approved PAP has been reviewed and revised to address the proposed mining activities under PRIO and their relationship and effect on any overlying AVF areas.