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:' ~.: ~ CO~ C MPANY A Cyprus Amu Compvry III IIIIIIIIIIIII III 7Ntentymile Coal Comparry 29515 Routt County Road N27 Oak Creek, Colorado 80467 970-879-3800 wt.a.+ F,`t, ~ P2oU -re z ~ RECEIVED October 27, 1997 Jerry Strahan Bureau of Land Management 1280 Industrial Avenue Craig, Colorado 81625 MAY 0 8 1998 Civision of Minerals & Geology RE: Resource Recovery and Protection Plan -Modification No. 6 Mine Plan Change Dear Mr. Strahan: Twentymile Coal Company is requesting a modification to its existing resource recovery and protection plan. The modification is dictated by the adverse mining conditions that have been encountered in longwall panels 9 Right and 8 right and in gateroads f0 Right, 9 Right, 8 Right and 7 Right. TCC believes these adverse conditions will continue as Panels 7, 6, 5,4, 3 and 2 Right and there associated gateroads are mined. These conditions are the result of the steep grades in this area. The grade varies from I S to 23 percent, and coupled with the fault that is immediately east of this steep gtade zone makes the mining of these reserves uneconomical and a safety concern. Historically, TCC identified these reserves as being in an area too steep for longwall mining and the BLM agreed with this contention. With the securing of lease CO-54608 TCC became aggressive with its thoughts on mining of the reserves located in this area. To date, TCC has mined in these areas in gateroads 7 Right through 10 Right and in longwall panels 9 Right and 8 Right. Unfortunately, the mining of these reserves proved to be uneconomic and unsafe. The factors impacting the economics include additional roof support required to mine up the steep grade, out of seam dilution which results in the majority of this coal being sent to the low quality coal stockpile, additional material handling cost due to having to wash the coal. reduced productivity resulting from the difficulty of moving the face up this steep section. Also. the safety hazards become more pronounced as TCC mines this coal due to the increased grades resulting in greater injury potential. The injury potential is associated with tripping and slipping hazards, body strains tr-om working on this steep grade and the increased hazard of roof failures. Also, with the additional cribbing that has been and will be done TCC increases the potential for back injuries and pinching type accidents. The modification impacts three leases, those being CO-54608, C-081330 and D-052547. The following table presents the number of acres and recoverable reserves for each of the leases. LEASE NUMBER ACRES RECOVERABLE RESERVES CO-54608 190 1,741,555 C-08 1330 247 ~?64,022 D-052547 38 348.311 TOTAL 475 4,353,888 We visited the longwall face on October 23 in order to provide you an opportunity to see the current conditions. The trip to the face was uneventful until we neared the active face. As is evident from this