2015-08-14_REVISION - C1982056

• Permit No: C1982056
• IBM Index Class Name: Revision
• Doc Date: 8/14/2015
• Doc Name: Adequacy Response 3
• From: Twentytmile Coal, LLC
• To: DRMS
• Type & Sequence: PR10
• Email Name: JLE
• Media Type: D
• Archive: No

TWENTYMILE COAL, LLC - FOIDEL CREEK MINE
PERMIT REVISION PR14-10
WOLF CREEK RESERVE DEVELOPMENT AND MINING
TECHNICAL ADEQUACY RESPONSE 3 - 08/15
Technical Adequacy Review 3
I a) Volume II, Volume II -A and Volume V-A table of contents pages submitted with the response has page
numbers v, vi, and xxv respectively. They should have page numbers iii, v and xxiv respectively based on a
review of the currently approved table of contents. Please revise these pages with the correct page
numbers.
Response: The referenced page numbers have been corrected, and copies of the corrected pages
accompany these responses for replacement in the PAP.
4b) Page 2.05-3 indicates that Twentymile Coal, LLC (TC) is pursuing leasing the Federal coal with a Lease
By Modification (LB4 for the inclusion of the Wolf Creek Seam in the Federal Coal Lease COC -54608.
The Division cannot approve a mine plan that includes mining in the Wolf Creek Seam within this area
until the LBM has been approved. Should the LBM not be approved by the time all other PR -10 adequacy
issues have been resolved, TCC will have to request continued extension of the decision due date until the
LBM is approved. This item remains outstanding and will need to be addressed prior to the approval of
PR10.
Response: TC recognized and discussed this constraint with the CDRMS at the time the PR10 application was
submitted. TC will monitor the status of the pending federal lease modification and coordinate with the CDRMS
relative to extension of the decision date for the PR, and submittal of the lease documentation when it becomes
available.
8b) Revised page 2.05-3.1 indicates the subsidence monitoring network for the longwall area is shown on Map
23a. The Division could not locate Map 23a within the permit application package. Please submit an
updated Map 23a. The Division appreciates the submittal of this map. The map submitted appears to be
Sheet I of 2 maps. The Division requests that TC submit the second of the two maps.
Response: Map 23a (Sheets 1 and 2) is an old mylar map which is not relevant to any of the current or
future mining operations. Given this consideration, we are providing a print of Sheet 2 for reference with
these responses.
I Ob) Revised Page 2.05-3 and 2.01-4 indicates the permit area is 22,447 acres and 22,607 acres respectively.
Revised page 2.01-4 appears to include the 160 additional permit acreage proposed with PR10. The
Division's records indicate the current permit acreage for the site is 20,100 acres and with the approval of
PRIG, the permit acreage will be 20,260 acres. Based on the Division's files, it appears TC reduced the
permit area with TR51 to 22,443 acres. TC requested to increase the permit area by 80 acres with TR81
for a total permit area of 22,530 acres. Subsequently, with Permit Renewal No. 6 (RN6), the permit area
was cited to be 22,450 acres. In the most recent technical revision, TR83, the permit area was cited to be
22,450 acres. Please review the permit acreage and permitting history and verify that the permit acreage
will be 22,60 7 acres with the approval of PRI0.
We spoke on the telephone on July 14, 2015 regarding how TC verified the 22,607 acres. Based on this
conversation, TC's draftsman calculated this area based on the permit boundary depicted on the mining
plan map #23. The original adequacy question indicated that TC requested to change the permit area by
80 acres with TR81, this was incorrect. It appears TC requested to increase the permit area by 80 acres
with TR82. Based on the Division's decision form for TR82, the Division approved an increase of 160