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<br /> <br />J. J. Dudash - 2 - January 17, 2001 <br />~/3 <br />BRL -Page 2.05-112 was amended to indicate a subsidence report will be <br />submitted to the Division the end of June and December for the preceding six <br />month period. <br />4. On revised page 2.04-35, it is stated in the last paragraph that Hubbard Creek will <br />be protected from the effects of subsidence. However, on revised page 2.05-104, <br />it is stated that Hubbard Creek could be damaged by subsidence cracks. Please <br />reconcile. <br />BRL -The statement that Hubbard Creek could be damaged by subsidence <br />cracks is a worst possible consequences description which precipitates a <br />subsidence control plan. The subsidence control plan, in this case limited <br />extraction, will protect Hubbard Creek from the effects of subsidence. <br />5. On revised page 2.05-104, it is stated that subsidence cracks could allow water <br />from Hubbard Creek to flow into the mine workings. It is further stated that such a <br />stream maybe repaired. If it happens that it is not possible to repair a subsidence <br />crack in a stream, or if it can be repaired only after a significant amount of water <br />enters the mine workings, how does this affect BRL's prediction of the potential <br />for mine water discharge to occur? Also, does BRL have enough water rights to <br />mitigate the loss of this resource, and has BRL accounted for a sufficient water <br />depletion estimate, if there is a significant diversion of surface water into the <br />underground workings? <br />BRL -The referenced statement on page 2.05-104 is a description of the worst <br />possible consequences of subsidence. Based on the possibility that a <br />subsidence crack could allow water from Hubbard Creek to flow into the mine, <br />BRL prepared a subsidence control plan in accordance with Rule <br />2.05.6(6)(b)(iii)(B}. Hubbard Creek will be protected by a limited extraction zone. <br />The limited extraction zone is defined by extending a safety zone a distance of <br />one hundred feet from the creek and then projecting a line down at the 25° angle <br />of draw until it intersects the coal seams. <br />Under Section 2.05.6(6)(b)(i)(C), please add a discussion of the possible effects <br />of subsidence on the intermittent and ephemeral drainages in the permit area and <br />how those effects might negatively influence the perennial drainages <br />BRL -The requested discussion was added to amended pages 2.05-104 & 105 <br />7. On revised page 31 of the "Subsidence Prediction" section and page 36 of the <br />"Subsidence Handbook" in Exhibit 15, please add the topic of streams to the <br />discussions concerning surface water resources. <br />BRL -Streams were added to the subsidence prediction discussion on amended <br />pages 31, 32, 36 and 37 in Exhibit 15. <br />