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Permit Revision Adequacy Comment Response <br />November 30, 2004 <br />Page 13 of 24 <br />add information on groundwater quality effects of mining at the West Elk Mine from data <br />gathered in the program. <br />MCC Response: MCC has updated the text. <br />2.05.6 (~ Subsidence Survey, Monitoring, and Control Plan <br />70. On page 2.05-92, the first pazagraph under "subsidence survey," a prediction is made for azeas <br />where only E-seam coal will be extracted. MCC should provide analysis and discussion for <br />those areas where both B-seam and E-seam mining aze indicated by Maps 51 and 52 in the area <br />directly north of the Minnesota Reservoir. <br />MCC Response: Discussion was added to clarify that the area alluded to is outside the <br />SOD Permit area. <br />71. Item 6 on page 2.05-96 discusses a subsidence survey but fails to note the year. Please add the <br />yeaz of the survey. <br />MCC Response: Text was revised to show 2003. <br />72. Page 2.05-101 contains a discussion of the mitigating effects provided by shale and claystone <br />. units on subsidence-induced surface cracks (and consequent water loss from the surface). Can <br />MCC provide any estimate of the proportion of these soft lithologies in the sequence overlying <br />the E-seam, particulazly in areas of thinner cover above the mined seam? Are there any <br />specific thick or persistent units identified? <br />MCC Response: MCC quantified and discusses the soft layers above the E Seam. <br />73. Related to the comment above, the third paragraph of page 2.05-188 states that the fractured <br />zone in the SOD azea will be less extensive than in the Box Canyon and Apache Rocks areas. <br />The implication is that there is a greater proportion of shale and claystone above the mined <br />seam in the SOD azea, but that is never stated directly. Please complete the discussion by <br />directly addressing the reasons MCC predicts that fracture zone height above the mined panels <br />will be less in the SOD area and provide reference to lithological variations or whatever other <br />reason is attributed to this prediction. <br />MCC Response: Text revised. <br />74. On page 2.05-109, in the first pazagraph, the statement is made that "areas of colluvium and <br />alluvium 5 to 10 feet thick were observed to cover cracks as much as 10-14 inches wide" in <br />earlier subsidence monitoring. Please add an explanation of how and where that was observed. <br />Were bedrock cracks observed to disappear beneath a cover of unconsolidated material? <br />MCC Response: Text was added and data are shown in the Alluvial Well completion <br />>~ reports. <br />