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-3- <br />Question No. l (continued) <br />The nett question pertained to Mr. ICrassa's comments in his Paragraph No. g, and to the status of our <br />review of We operator's subsidence predictions. <br />Mr. Krassa has requested the operator provide a map showing the pay thickness and lateral extent of <br />the coal seam. 'Ihe operator, however, is not required to provide this information. The relevmt <br />regulation in the matter regarding a map with coal seam thickness and eztwt is 2.04.6(3)(a). Neither <br />a map showing the lateral ezleat of the coal seam nor m isopach map indicating the pay Wickness of <br />[he coal seam is discussed. Operators may idwtify coal seam thickness with across-suction, which <br />Basin has done. <br />The expected surface extent of potential subsidence effects has been identified by the operator on the <br />'Structure Inventory Map.' 'Ibis predicted ezttnt of subsidence effxts was derived using m mgle <br />draw of 30 degrees, as described in the operrtor's subsidence survey submitted pursuant to <br />Rule 2.05.6(6)(e). In addition, a 500-foot buffer zone around the mgle of draw zone has been drawn <br />on that map, and all atrtredrres within the 500-foot buffer, as well as within the expoclcd mgle of <br />draw area, were listed in the s[rtrcttrre inventory. Further, the operator, in consultation wish <br />S-h P Tim Pendleton, has submitted a proposed monitoring program to verify the conclusions of the survey. <br />N we are still reviewing these su mt ss <br />2. Desautel's Letter of February 24. 1994 <br />A question was raised as to whether water monitoring in the Rmcho Escondido arcs was necessary given the <br />Division's review of the Golden Eagle Mine PHC and CHIA. this question concerned Jeff Desautel's <br />comments in Paragraph No. 5 of his February 24, 1994 memo. - <br />The answer is the same es the answer regarding Mr. ICrassa'e commrnts ru Paragraph No. 6 of his <br />letter of Februvy 25, 1994. <br />3. Krassa's Letter of February 22. 1994 <br />A question was asked regarding the status of the operator's compliance with Rule 2.05.3(2)(b). This was in <br />_ _respQnse to Mr. ICrassa's comments in Paragraph No. d of his letter of February 22, 1994. <br />Rule 2.05.3(2)(b) requurs maps and narrative that describe the proposed surface disturbmces <br />associated with rho underground mining operation to be submitted with the application. Map 12, <br />/vt /~ 'Surface Disturbance and Post-Mining Land Use', is being updated by the operator to include twos ~r <br />shafts, several degas wells and their associated coeds on the north side of Highway 12. <br />~ 9- P z) <br />It is my understanding that Raton West believes that areas of proposed subsidence should be shown <br />on the surface disturbance map. However, the defurition of disturbed errs, Rule 1.04(36), states in <br />paR that a disturbed area rrsults from removal of vegetation, topsoil or overburden. 'therefore, <br />subsidence areas are sot considered disturbed areas,~md do_not appear to be refired to be_ showp~p <br />~e surface dtsturbance <br />A second question was asked concerning the last paragraph of the February 22, 1994 letter from <br />Mr. ICrasaa, regarding the status of materials that were to be submitted to the Division on <br />February 21, 1994. <br />The answer to this question is the same es the answer W the question regarding Mr. Krassa's <br />comments in Paragraph No. 3 of his February 25, 1994 letter. <br />/ero <br />M:\oss\em\c81013.jd <br />