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TWENTYMILE COAL, LLC — FOIDEL CREEK MINE (C-82-056) <br />MR16-297 FISH CREEK BOREHOLE COAL FINES CLEANUP <br />TECHNICAL ADEQUACY RESPONSES (06/16) <br />1.) Proposed revised page 2.05-50 3 includes a change in the lvcrter treatment methods to be utilized at <br />the Fish Creek Borehole to include treating the ii iter pinnped from the mine with a flocculent. <br />This proposed change is not associated iiith the cleanup of'the mine water discharged from the <br />pump resulting in the notice of violation CV -2016-001. Please remove this change in the revised <br />text regarding the water treatment method This change will need to be processed under a <br />separate technical revision. <br />Response: The language referencing and discussing the use of flocculants to treat mine water has <br />been deleted, and based on discussions with the CDR -MS re: timing constraints and mine dewatering <br />operational and safety considerations. a separate Minor Revision will be prepared and submitted to <br />address these considerations. Copies of the revised PAP text page(s) accompany these responses. <br />2.) Proposed revised page 2.0j-50.10 ends with the last paragraph of the 19RT Detivatering Borehole <br />and Pipeline section. As proposed, a large portion of'the 5 -Allain North Borehole and Pipelines <br />and Future Passive Water Treatment System OVIR14-283, MRI S-288, and MR16-295) section <br />ivould be cut out of the permit. Please review the organization andpagination of these proposed <br />pages and update as necessary to insure text is not deleted or removed. <br />Response: The referenced text has been reviewed and revised to address the inadvertent text <br />omission. Copies of the revised PAP text page(s) accompany these responses. <br />3 ) Twentvmile Coal proposes to update Hap 23c of'the permit once the cleanup activity has occurred <br />in order to accurately depict the neiv surface disturbance boundary. The Division believes Map 29 <br />would also be appropriate to revise to depict the change in the disturbance area. The Division will <br />stipulate the approval of this revision so that the updated maps 23c and 29 be submitted ivithin 15 <br />days of i hen the cleanup activity is completed. <br />Response: As requested, TC will also revise Map 29 to reflect the change in disturbance area. <br />4.) Proposed revised page 2.03-50.4 indicates that the coal fines will be cleaned up and transported to <br />a bermed basin on the adjacent IS -Left Shaft Pad. The Division believes this area is currently <br />being used as temporory storage.for pond cleanings and should only be a temporary storage area <br />for these fines. Please revise this page to indicate ivhere these coal fines will be taken for final <br />reclamation. <br />Response: The referenced text discussion has been review and revised to clarify that placement of <br />coal tines at the 15 -Left location is temporary, and that these materials will subsequently be moved to <br />another location for permanent placement. Copies of the revised PAP text page(s) accompany these <br />responses. <br />