2021-11-02_REVISION - C1981012 - Laserfiche WebLink

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New Elk Mine, PR5 Adequacy Review 2 November 2,2021 Page 10 of 11 with the performance standards of Rule 4.20. Please update the Map 20 series,Map 11,Map 12,Exhibit 8, Exhibit 24,Exhibit 42,Table 19,and any other applicable information in the PAP as necessary. The cover letter for PR5 indicates subsidence is not expected since no secondary mining will occur,please provide a demonstration this assumption is correct specific for the Blue Seam. a. NECC Response: Section 2.05.6(6) has been revised to indicate that mining in the Blue Seam will include only room and pillar mining with no secondary recovery.As a result,no subsidence will occur. The referenced sections of the PAP have been revised accordingly. b. DRMS Response: i. Section 2.05.6(6)of the PAP was not updated with PR5 or the adequacy response,and NECC will need to revise this section of the permit for the proposed change in the mine plan. Simply stating that no secondary extraction will occur and therefore subsidence will not occur is not adequate. Exhibit 24 is designed based on a previously approved mine plan submitted with TR58 and needs to be revised based on NECC proposed PR5 mine plan and NECC methods of mining. Exhibit 42 needs to be updated. The revised subsidence survey, monitoring and control plan must comply with Rule 2.05.6(6),since NECC is asserting that no subsidence will occur based on the PR5 mine plan,please provide a technical analysis/demonstration to substantiate this. ii. The information provided in the adequacy responses does not include any new information regarding the development mining underneath the Purgatoire River. The existing information in the PAP only covers the previously mined coal seams and does not account for the Blue Seam. The Blue Seam is roughly 250-300 above the Apache Seam. New information regarding undermining the Purgatoire River in the Blue Seam needs to be addressed and included. This should include depth of the Blue Seam from the Purgatoire River in the areas planned to be over the mining areas. As well as,if/what type of measures taken to prevent impacts to the hydrologic balance. i. Regarding the Map 20 series maps,these maps must be certified by a qualified registered professional engineer or professional geologist,with assistance from experts in related fields such as land surveying and landscape architecture in accordance with Rule 2.10.3(2). Please revise the maps accordingly to include this certification. The Division received proof of publication of the notice required by Rule 2.07.3(2)for the PR5 application. The last date of newspaper publication was August 4,2021. The public comment period closed on September 3,2021,thirty days after the last date of newspaper publication. The Division is required to issue a decision on the application by November 4,2021. If you need additional time to address the Division's adequacy review please request an extension of the decision date. If the decision date arrives and there are outstanding adequacy review items,the Division will issue a proposed decision to deny the application.