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-~- Rule 2.05.3(2) Operations Description In response to our last adequacy comment, requesting additional description of the planned escapeways and raises described on amended pages 4-26 and 4-26a of the permit application, the applicant has proposed to commit to approval of plans prior to any construction. This would be acceptable, if page 4-26a were appropriately amended to state the applicant's commitment, as contained within the second response letter. Rule 2.05.3(6)(a) Use of Explosives In response to our earlier comments, requiring an appropriate submittal in response to the requirements of Rule 2.05.3(6)(a)(i) through (vii), the applicant has submitted additional information. The amended application's pages 4-63a through 4-63u satisfy those requirements. Storm King Mining, Inc. has also indicated a proposed explosives bunker location on Figure 4.2-3 of the amended application. In preparing our eventual findings, we should include reiteration of Storm King's commitments to conduct pre-blasting surveys of all structures within Riverbend Subdivision, prior to conducting any blasting operations at the site (page 4-63a). Further, the applicant comments in the second response letter that they are willing to commit to the performance of pre-blasting surveys for any structure within the "general proximity of the blasting area", outside the strictly required one half mile limit. Unfortunately, the permit application's page 4-63a has not been appropriately amended to indicate this broader commitment to the performance pf pre-blasting surveys. Rule 2.05.3(8) Coal Processing and Non-Coal Processing Waste The applicant has submitted a letter-form mine plan schedule amendment which appears to propose division of the original mine plan into two Phases, A and 6. Phase A would include the development of a test mine, without the coal processing slurry embankment. First, I believe the entire permit application would require extensive revision to properly indicate the phasing of the mine plan. Second, I do not believe it appropriate to permit mining of coal without an appropriately approved disposal structure to receive the inevitable waste generated by an hydraulic coal mining operation. In my earlier response review I indicated that the applicant had submitted the majority of the information required to comprise a "general plan" for the coal processing waste embankment, as described in Rule 2.05.3(8)(a). With the addition of a "certification statement that includes a schedule setting forth the dates that any detailed design plan ... will be submitted to the Division the general plan would be complete. Amendment of the design to yield the required seismic safety factor [see comment (1) below] would then render the general plan technically adequate. The applicant has not, however, completed a "detailed engineering design", as described in that same rule.