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2015-11-27_REVISION - C1982056 (3)
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2015-11-27_REVISION - C1982056 (3)
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Last modified
8/24/2016 6:12:57 PM
Creation date
11/30/2015 9:25:28 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1982056
IBM Index Class Name
Revision
Doc Date
11/27/2015
Doc Name
Adequacy Responses
From
Twentymile Coal, LLC
To
DRMS
Type & Sequence
PR11
Email Name
JLE
DIH
Media Type
D
Archive
No
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12. Site 900 appears to be within the 4RT longwall panel of the WCR affected area along Foidel Creek. <br />Given this, it would not serve as an appropriate downstream monitoring station for Foidel Creek. <br />Please revise the monitoring plan to monitor a site that is downstream of the WCR affected area but <br />upstream of the confluence of Middle Creek. <br />Response: Refer to previous response to Item 10. <br />13. The monitoring frequency for Site 8 and 900 do not match the monitoring frequency currently <br />approved in Exhibit 14 in the permit for these sites. Does TC intend to conduct additional <br />monitoring in accordance with the proposed plan submitted with Exhibit 4E-11 ? If so, please revise <br />the water monitoring plan currently approved to match what is proposed in Exhibit 4E-11. <br />Response: The referenced exhibits have been reviewed and revised for consistency, relative to monitoring <br />frequency. Copies of the revised exhibit materials accompany these responses for replacement in the PAP. <br />14. Please revise the monitoring plan to indicate when the ponding and vegetation monitoring plan will <br />be suspended. <br />Response: The WCR Monitoring plan has been reviewed and revised to clarify the period of monitoring for <br />potential ponding and vegetation changes. Copies of revised Monitoring Plan materials accompany these <br />responses for replacement in the PAP. <br />Rule 2.04.4 - Cultural and Historic Resource Information and Rule 2.05.6(4) — Protection of Public Parks <br />and Historic Places <br />15. PRII requests an increase in affected area of 150 acres. TC hired Metcalf Archaeological <br />Consultants, Inc. to conduct a Class III Cultural Resources Inventory for the newly proposed <br />affected area. The Division received the results of this inventory on August 21, 2015. These results <br />have been forwarded to the State Historic Preservation Officer's office (SHPO) for review and the <br />Division is awaiting their response. The following item will need to be addressed: <br />a. According to the inventory, two sites; 5RT3324 and 5RT3325 are recommended to be <br />eligible for inclusion on the National Register of Historic Places (NRHP) and total <br />avoidance is recommended. These two sites are within the area that will be affected by <br />subsidence. It does not appear surface disturbance activities other than possible impacts <br />from subsidence will occur in these areas. TC, the Division and SHPO will need to <br />coordinate to determine if appropriate mitigation and treatment measures are necessary <br />prior to undermining these areas. If mitigation and/or treatment measures are necessary for <br />these sites, a discussion of such measures will need to be included in Section 2.05.6(4) of the <br />permit. <br />Response: Section 2.04.4 has been reviewed and revised to reference and discuss the results of the <br />supplemental cultural resource survey covering the additional subsidence area. The recommended eligible sites <br />are lithic scatters with demonstrated potential for buried cultural material. TC requested that our archaeological <br />consultant, Metcalf Archaeology, review their information regarding the subject sites, and provide an <br />assessment of the potential for adverse impacts to these sites from the anticipated mining -related subsidence. <br />On 11/03/15, Metcalf submitted a letter to the CDRMS summarizing their evaluation of potential subsidence - <br />related impacts on the identified NHRP eligible sites. Given the very limited potential subsidence displacement <br />and change in gradient for the subject sites, Metcalf indicates that potential subsidence effects would be <br />negligible. <br />
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