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Mr. William T. Davis - 4 - April 25, 1989 <br />The operator presents a brief discussion of its plan to remove overburden <br />above old shallow underground workings using a small dragline and "light load" <br />equipment to clean exposed coal. If the intention is to suggest that surface <br />equipment would operate above underground workings covered by thin quantities <br />of roof coal, the operator will need to elaborate on this plan to demonstrate <br />that such an activity is safe to the miners, and feasible to conduct. The <br />following questions have been asked by the State Division of Mines: Can the <br />dragline cause failure in the tributary support system? Would the dragline <br />tip or overturn in a subsidence channel? How will "light equipment" actually <br />work successfully and safely to clean the coal surface? What measures are to <br />be taken to inform and train miners about the old workings? What safety <br />equipment will be kept on site? <br />The operator alludes to both a permanent spoil pile and a temporary overburden <br />storage pile at various locations throughout the application. It is logical <br />that some spoil storage will be necessary to develop the initial 1.5 acre <br />pit. A permanent Excess Spoil Pile can only be approved in accordance with <br />Rule 4.09, however, if the material is not required to achieve approximate <br />original contour within the mined area. Based upon the limited material <br />balance information contained within the application, it appears that a <br />deficit of bulked spoil will occur rather than an excess. Numerous scenarios <br />for material movement might result in temporary storage of spoil for later <br />regrading. The operator will need to amend the application to present a clear <br />plan for the movement, storage and placement of spoil materials during the <br />project life. A projection of mass balance, including projected bulking of <br />excavated material should be included within the application, in accordance <br />with Rule 2.05.3(6). If spoil storage is anticipated, the applicant should <br />also provide the information necessary to comply with those requirements, also <br />contained in that same rule. <br />The discussion of mine facilities is inadequate to satisfy the requirements of <br />Rule 2.05.3(3). The applicanrt should thoroughly describe the intended surface <br />facilities, including a map of the intended configurations. Items such as all <br />structures, conveyors, coal storage piles or structures, non-coal waste <br />storage and disposal, shops, and any loadout facilities should be described <br />and located. <br />Rule 2.05.3(4) <br />It appears from the operation's pl <br />Gulch is anticipated. In order to <br />that occurs in the drainage during <br />describing this diversion relative <br />diversion and the restored channel <br />4.05.4 must be provided. <br />sn that mining in the channel of Engleville <br />do this, the diversion of any water flow <br />the operation must be made. A plan <br />to the mining operation and designs of the <br />that comply with the requirements of Rule <br />A longitudinal profile for the restored channel and the anticipated flow <br />___: - velocities to be accomodated must be provided in order that stability be <br />assured through proper riprapping, etc. <br />