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TWENTYMILE COAL COMPANY - FOIDEL CREEK MINE TECHNICAL REVISION TR04-44, 18 RIGHT VENTILATION SHAFT TECHNICAL ADEQUACY RESPONSES (SET 2A) -SEPTEMBER 2004 Responses to Items 62. 63. 64. 65. 67. 68. 70. 72. 73. and 75 are complete and adequate Review of vour responses to Items 66. 71. and 77 is incomplete. nendine receipt ofthe mans With regard to /tem 61 of, oy ur response. Please see Rule 4.07.1(1). Please add [suggest as a last line to line S ofpage 2.04-50.1 (OS/06/04)J that the holes were backfilled with cuttings. Response: Given the very limited disturbance and very temporary nature of the subject soil sample holes, the "...otherwise managed " provision of Rule 4.07.1(1) appears applicable and is certainly more than adequate to achieve the stated objectives under this Rule. The referenced text revision has been incorporated as an accurate reflection of the work completed in the field. With regard to Item 69. Please revise topsoil volume figures on page 2.05-84.2 (08/18/04) as well. There is a diminishing relationship between permit area, permitted disturbance area, and area of actual disturbance. We have suggested that the permitted area of disturbance for the access road be the 100 foot-wide corridor to allow you flexibility to accommodate field conditions. A gualifted 35- foot-wide disturbance of "in most cases", "typically -will fall within", "will generally correspond" does not define the limits of permitted disturbance nor quantify the disturbance for reclamation cost estimates. Please clarify the text to quantify what area of permitted disturbance is proposed. The approved area of disturbance and the reclamation cost estimate will reflect this figure. Response: The topsoil figures provided on page 2.05-84.2 match the corresponding figures on page 2.05-45.4 and Table 49A. Until the road is built, the actual limits of disturbance are not known with certainty. With the 100' wide permitted road corridor and the 35' wide road disturbance area, we have tried to reasonably bracket the anticipated road disturbance. We can be reasonably certain (and will manage construction to assure) that there will be no road disturbance outside of the 100' corridor. Because the road follows the natural terrain, cut and fill requirements will be limited, both in terms of cut/fill requirements and the length and number of road segments for which cut/fill will be necessazy. As shown by the typical road cross-section on Map 1 W, average road running surface width will be approximately 24'-26'and the width of the road and ditch foot print with limited cut/fill will be approximately 35'. For purposes of estimating topsoil handling requirements, the 35' width figure represents a reasonable average over the 7,1001ength of the road. This approach meets the applicable regulatory intent and requirements by; 1) Cleazly defining the maximum limits of disturbance; and 2) Providing a reasonable basis for estimating material movement quantities and corresponding bonding costs. With regard to Item 74. Please add final pit closure as-built certifications here (change "--following temporary closure. "to read " following temporary and fnal reclamation closure.'), or to revised (09/08/04) page 2.05-106 (suggest as an addition to line 41). Resaonse: The referenced text has been revised, as noted.