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Rule 2.05.4 Surface and Groundwater Monitoring <br />This section of the Rules is actually the reclamation plan. I have <br />include my review of the proposed monitoring program under Section <br />2.05.6 below. <br />Rule 2.05.6 Subsidence Monitoring <br />1. On page 2.05-102, the operator states their are no <br />structures within the Apache Rocks area. On page 2.05- <br />121 the operator states there are structures. The permit <br />text should be corrected to be consistent as to the <br />presence of structures in the Apache Rocks area. The <br />Division's definition of structures is any man-made <br />feature. This includes existing roads, ponds, wells and <br />flumes. The operator has not defined any roads in the <br />area. Is this true? <br />2. The operator should not state that there will be no <br />material damage because they will fix it. Permit text <br />should estimate the damage and include as part of the <br />subsidence control plan details of the plan to repair or <br />replace. <br />3. On page 2.05-119 language should be added that states <br />that reduction in subsidence monitoring will be done via <br />a technical revision. <br />4. Page 2.05-122 includes references to items shown on ?. <br />The operator should correct this oversight. <br />5. The operator has provided information relative to the <br />depth of cracks but has not provided estimates of the <br />range of crack widths which could occur. Based on site- <br />specific observation, crack width could dramatically <br />affect the ability of the land to "heal itself". The <br />operator provided annual sediment yield calculations for <br />the affected surface drainages. Assuming a one crack 300 <br />feet long, 200 feet deep and 6 inches wide, natural <br />"healing" from sediment loss would take anywhere from 20- <br />139 years to heal, rather than " a few months" as the <br />operator indicates on p. 2.05-148. This assumes that one <br />crack located at the watershed outlet traps 100 percent <br />of the sediment lost from the watershed. Based on the <br />13-18 feet of subsidence predicted in parts of the Apache <br />Rocks area, I do not agree that natural healing will play <br />a significant role in subsidence repair. Evidence and <br />studies suggest that massive fracturing may occur, <br />especially on perimeter boundaries and over rigid <br />pillars. Large fractures 2-4 feet in width and 200 feet <br />deep pose a significant hazard for the land uses of the <br />area. I recommend we proceed cautiously in this area to <br />make sure that the probable impacts of subsidence are <br />appropriately addressed. One place to start is to ask <br />