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TC's Response: The PR14-10 submittal did not include Map 23 (relevant map showing the Wolf Creek
<br />Mining area was labeled Map 23 in the original submittal, but was corrected to Map WC23, since Map 23
<br />shows the entire Twentymile Mining Area). The most recent update to Map 23 was for TR13-83 (map
<br />revision identified as 01/24/14). This map includes the two permit boundary modifications noted in the
<br />comment above. The Permit Area was noted in TR13-83 (both pages 2.01-4 and 2.05-3) as 21,447 acres.
<br />With the addition of 160 acres for PR14-10 in Sections 12 and 13 (TSN, R86W), the total Permit Area
<br />acreage should be 22,607.
<br />Division's Response: Upon further review, the large difference in permit acreage the Division has been
<br />recording and what Twentymile Coal has determined seems to have originated with Permit Renewal
<br />Application No. 3 (RN3), Permit Revision No. 5 (PRS) and subsequent revisions. It appears the Division
<br />requested the permittee to clarify the permit acreage with RN3 and there was a decision made on what the
<br />permit area should be. However, I cannot determine for certain what the final decision was based on the
<br />information in the Division's file for RN3. But, PRS and RN3 were under review at about the same time
<br />period and PRS was approved two months after RN3 was approved. When PRS was approved, permit page
<br />2.01-4 was updated with a revised permit area of 23,040.9 acres. Technical Revision No. 33 (TR33) was
<br />submitted during the review of PRS and was approved prior to PR5 and added 7.2 acres to the permit area.
<br />The date on revised page 2.01-4 is prior to the date TR33 was submitted. TR33 did not update page 2.01-4 so
<br />it is likely the 23, 040.9 acres from PR5 does not include the 7.2 acre addition from TR33. By adding the 7.2
<br />acres, the total permit area should have been 23, 048.1 acres with the approval of PRS. The Division's
<br />decision form does not appear to have been updated with the correct permit area when RN3/PR5 was
<br />approved. PR6 requested to increase the permit area by 560 acres. This revision was approved but it does
<br />not appear the Division's decision form accounted for the increase in acreage. With the approval with PR6,
<br />the permit area should have been 23, 608.1 acres (23, 048.1 + 560 acres). Then, TR51 reduced the permit
<br />acreage by 1,320 acres. During the review of TR51, the permittee submitted MR205 which should not have
<br />changed the permit acreage. When the Division approved MR205, the decision form indicated a permit area
<br />that was 1,320 acres less than the previously approved permit area. Subsequently the Division approved
<br />TR51 and reduced the permit area again by 1,320 acres. Given this, it appears the 1,320 acres was
<br />inadvertently reduced twice from the Division's records. When TR51 was approved, the permit acreage
<br />should have been 22,288.1 acres. Subsequently, with TR82, the Division approved a 160 acre increase in the
<br />permit boundary yielding a permit area of 22,448.1 acres (22,288.1 + 160 acres). PRIO requests an
<br />approval of a 160 acre increase in the permit area. By adding 160 acres to 22,448.1 acres, the total permit
<br />area should be about 22, 608.1 acres. PR10 indicates the permit area should be 22,607 acres. The 1.1
<br />difference in acreage is likely due to a rounding error. The Division will fix the discrepancy in our records.
<br />Also, the Permit Renewal No. 6 (RN6) application listed the mineral and surface ownership acreage by
<br />ownership (Federal, State and Private acreage). The table below depicts this information.
<br />RN6 Federal
<br />State Private Private TOTAL
<br />Application
<br />PR10+
<br />Surface 6070
<br />7613 8767 160 22610
<br />Mineral 8478
<br />7758 6214 160 22610
<br />There is a discrepancy of three acres between what TC indicates the permit area should be and what the sum
<br />of the ownership acres yields. Please review the ownership acreage (both surface and mineral) and update
<br />the information so that the total ownership acreage equals the 22,607 acre permit area.
<br />TC's Response: As a practical matter, when dealing with Permit Area and ownership acreages, because the
<br />number are relatively large, TC has always rounded to the nearest whole acre, a practice which has been
<br />accepted by the Division. The referenced difference between the ownership acreage provided in the Permit
<br />Renewal application and the cumulative acreage carried forward for the Permit Area reflects this rounding
<br />convention, is negligible given its relative magnitude (3 acres/22607 acres = .000133 or .0132%), and does
<br />not require adjustment. From a practical standpoint, the only acreage figures that are of significance are the
<br />surface disturbance and affected area acreages, which are normally carried out to one decimal point, since
<br />they relate to reclamation obligations under the permit.
<br />Division's Response: The Division agrees the difference in surface/mineral ownership acreage and permit
<br />area acreage is negligible. Upon discussion with Division management, if PRI0 is approved the permit area
<br />will be increased to match the surface/mineral ownership acreage.
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