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REV14280
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REV14280
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Entry Properties
Last modified
8/25/2016 1:25:28 AM
Creation date
11/21/2007 10:50:27 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1982056
IBM Index Class Name
Revision
Doc Date
9/10/2004
Doc Name
Adequacy Response
From
Jerry Nettleton
To
Byron Walker
Type & Sequence
TR44
Media Type
D
Archive
No
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With regard to Item 76. Please revise page 2.05-45.5 (09/08/04), line 23, to indicate that the materials <br />excavated for the collar of the shaft will be placed in the prepared (excavated) cuttings pit. <br />Response: With respect to both Items 76 and 73, we want to reiterate that the materials that will be <br />removed during shaft collar excavation will be unconsolidated overburden materials that are no <br />different (relative to their chemical and physical chazacteristics) from the overburden materials placed <br />as surface mined spoils in conjunction with the previous surface mining operations in the azea. Based <br />on area lithology, the excavated shaft collar materials will not contain coal or cabbonaceous materials <br />and have been determined to be non-acid and non-toxic forming, as documented in Section 2.04.6(3) <br />of the PAP. <br />It is important to note that the regulatory definition of "Underground Development Waste" under Rule <br />1.04(143) specifically designates "....waste rock mixtures of coal, shale, claystone, siltstone,..." <br />(underline and bold added for emphasis). In addition, the specific regulatory provisions for "Coal <br />Mine Waste Banks" and "Coal Mine Waste Dams and Embankments" (Rules 4.10 and 4.11.5) focus <br />on protection/mitigation for potential health, safety, and environmental hazards specifically associated <br />with mixtures of coal, carbonaceous materials, and other geologic materials (ie: combustion and acid- <br />or toxic-formation and drainage). Since the excavated shaft collar materials will not contain coal or <br />cabbonaceous materials, we feel very strongly that blanket application of the "Underground <br />Development Waste" definition and associated regulatory requirements is inappropriate and <br />unnecessary relative to practical health, safety, and environmental protection objectives. <br />Not withstanding the above considerations, and in order to facilitate timely approval of this Technical <br />Revision application, TCC will agree to place the shaft collaz excavation material in the lined cuttings <br />pit, and has modified the text discussion accordingly. <br />With regard to Item 77. Please add in the legend to Map 1 W-50 the yellow contour lines identified as <br />original (undisturbed) and post-mining topographic contours. <br />Response: The noted change has been made in the legend of Map 1 W-50. <br />
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