Laserfiche WebLink
Twentymile Coal, LLC. <br />Page 4 <br />July 21, 2015 <br />a. TC's response: The referenced subsidence monitoring network was associated with the <br />initial validation of the subsidence and impact analyses for undermining the Fish Creek <br />AVF and verification that the longwall mining activities would not adversely impact the <br />"essential hydrologic function". Copies of Map 23A are being provided with this <br />response submittal as a historic reference document, however, there is no need to update <br />this map, as it is not directly relevant to the activities proposed under PR10. <br />b. Division response: The Division appreciates the submittal of this map. The map <br />submitted appears to be Sheet 1 of 2 maps. The Division requests that TC submit the <br />second of the two maps. <br />9. Revised page 2.05-3 indicates the total disturbed area is approximately 640 acres. The Division's <br />records indicate the total disturbed area to date is 734.22 acres. Please review and verify your <br />disturbed area acreage. <br />a. TC's response: Please refer to the previous response to Comment 2. Revised copies of <br />the referenced page accompany these responses for replacement in the PAP. <br />b. Division's response: Item resolved. <br />10. Revised Page 2.05-3 and 2.01-4 indicates the permit area is 22,447 acres and 22,607 acres <br />respectively. Revised page 2.01-4 appears to include the 160 additional permit acreage proposed <br />with PR10. The Division's records indicate the current permit acreage for the site is 20,100 acres <br />and with the approval of PR10, the permit acreage will be 20,260 acres. Based on the Division's <br />files, it appears TC reduced the permit area with TR51 to 22,443 acres. TC requested to increase <br />the permit area by 80 acres with TR81 for a total permit area of 22,530 acres. Subsequently, with <br />Permit Renewal No. 6 (RN6), the permit area was cited to be 22,450 acres. hi the most recent <br />technical revision,TR83, the permit area was cited to be 22,450 acres. Please review the permit <br />acreage and permitting history and verify that the permit acreage will be 22,607 acres with the <br />approval of PR10. <br />a. TC's response: The Permit Area acreage figure has been checked and updated for <br />consistency. Revised copies of the referenced page accompany these responses for <br />replacement in the PAP. <br />b. Division's response: We spoke on the telephone on July 14, 2015 regarding how TC <br />verified the 22,607 acres. Based on this conversation, TC's draftsman calculated this <br />area based on the permit boundary depicted on the mining plan map #23. The original <br />adequacy question indicated that TC requested to change the permit area by 80 acres with <br />TR81, this was incorrect. It appears TC requested to increase the permit area by 80 acres <br />with TR82. Based on the Division's decision form for TR82, the Division approved an <br />increase of 160 acres. It is unclear why there is a discrepancy in how many acres TC <br />requested to increase their permit area by and how many acres the Division ended up <br />approving. Given this, I compared the permit boundaries depicted on Map 23 approved <br />with TR82 and the map that was previously approved prior to TR82 which appears to <br />have been revised with TR78. It appears the permit boundary was modified in two areas <br />based on these maps. One area is located in the NE 1/4 of Section 34 of TSN, R87W. The <br />