2018-07-10_REVISION - C1980007

• Permit No: C1980007
• IBM Index Class Name: Revision
• Doc Date: 7/10/2018
• Doc Name: Adequacy Review Response
• From: Mountain Coal Company
• To: DRMS
• Type & Sequence: PR15
• Email Name: LDS
• Media Type: D
• Archive: No

Mountain Coal Company
Mountain Coal Company, LLC
West Elk Mine
5174 Highway 133
Somerset, CO 81434
Kathleen G. Welt
Environmental Engineer III
kwelt(Marchcoal.com
phone: [phone]
Please update the text and Exhibits 10 and 11 with information pertaining to the permit
area expansion proposed with PR -15.
The following statement was added to page 2.04-8. "Additional block clearance surveys of
the lands that overlie proposed E seam longwall panels SS1 through SS4 will be conducted by
ERO during July 2018. The findings of that investigation will be documented in Exhibit 1 OF."
Rule 2.04.11 — Fish and Wildlife Resources Information
5. Fish and wildlife resources information for the permit area is given on pages 2.04-162 through
-180 and in Exhibits 34 through 38A of the currently approved PAP.
Please review the text of pages 2.04-162 through -180 and associated exhibits, and
update as necessary.
The information contained in section 2.04. 11 remains valid. The following statement
was added to page 2.04-162. "Additional information on wildlife species within the area of the
Southern Panels (E seam longwall panels SS1 through SS4) can be found in the Supplemental
Final Environmental Impact Statement for Federal Coal Lease Modifications COC -1362 and
COC -67232, dated August 2017 (See
https://www.fs.usda.gov/nfs/11558/www/nepa/68608 FSPLT3 4051445 pd.)"
Rule 2.05.3 — Operation Plan
6. Rule 2.05.3(2)(b) requires a detailed narrative, cross section, map(s) and timetable(s)
sufficient to describe the areal extent of the proposed underground workings.
Please update Map 51 E -Seam Projected Operations. The map should present a coherent
mine plan including identifiable panels, shaded to indicate the time at which they are
projected to be mined. The feature "Area of Potential Longwall Panels Extensions Based
on Future Additional Exploration" should be removed from the map. The features
"Approximate Limit of the Maximum Predicted 190 E -Seam Angle of Draw", "Maximum
Projected Areal Extent of Potentially Mineable E -Seam" and "Projected E -Seam Mining"
should be updated.
Map 51 has been updated with revised E seam longwall panels SSI through SS4 and
includes the lines for the approximate angle of draw and the projected areal extent of potential
mineable E seam.
7. On proposed page 2.05-4, in the fourth paragraph, the final sentence reads "The overall
recovery of the mine layout has not been calculated, because it varies continuously with
changes in mine plans."
Please replace the sentence on page 2.05-4 with a narrative estimate of the coal to be
recovered, including all assumptions, using a range of values if necessary, based on the
mine plan proposed with PR -15.
This statement on page 2.05-4 was a remnant from past (early B seam and E seam)
panel layouts and is no longer valid. Table 28 and paragraphs two through four have been
revised to provide the estimate of the remaining B seam and E seam recoverable coal reserves.
8. Table 28 — Estimate of Recoverable Coal Reserves at the West Elk Mine, and Table 32 —
Projected Employment Needs at West Elk Mine for the Life of Mine provide important
information about the mine plan.
Please review tables 28 and 32 in the light of responses to items (1) and (2) of this letter,
and update as necessary.