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<br />MAY 15, 2002, MID-TERM FOLLOW-UP ITEMS
<br />2.05.6(6) Subsidence Survev. Subsidence Monitoring, and Subsidence Control Plan
<br />16. Please update the narrative within Section IILA.7.j of the permit application as appropriate, on
<br />page III-21. Specifically, amend the statement in pazagraph 2, that "The effect of subsidence on
<br />the groundwater under Red Wash and Scullion Gulch is unpredictable and purely speculative", to
<br />address the effects documented by monitoring of the Red Wash alluvial wells. In addition, please
<br />amend the narrative of paragraph 4 to describe visual monitoring conducted and observed effects
<br />of longwall retreat mining on Panel LW-1B, beneath Scullion Gulch and Raven Park Reservoir.
<br />17. Please amend the 2001 Annual Subsidence Report to include a discussion of the above referenced
<br />monitoring and observed effects, and include pertinent photographs, as specified in the permit text.
<br />Permit Organizational Items
<br />18. Our copy of Permit Volume I, Section II.B., Geology, contains certain information not listed in
<br />the Section Table of Contents. This information begins following Table II.B-2 on page II.B-14,
<br />and includes Figure II.B-2 "Typical Cross Sections of the Coal Seams", Appendices 8 and 9
<br />(pages II.B-23 through II.B-52), and descriptive and analytical information for a number of drill
<br />holes, on un-numbered pages following page I[.B-52. We notethat Appendices 8 and 9 aze
<br />referenced in the permit text on page II.B-6.
<br />Please address the appazent discrepancies between the Section Table of Contents and the actual
<br />contents described, and amend as appropriate. Also, please address the nature of the appazently
<br />missing Appendices 1 through 7 (pages II.B-15 through 22), and submit those pages if warranted.
<br />19. Our Permit Volume 5 contains two distinctly different versions of Map 32 "Typical Drainage
<br />Structures Sections and Details" (Drawing No. D-346-C-109). One copy, labeled REV.2, has a
<br />copied certification by Don M. Williams, dated 2-20-81. The other copy, labeled REV. B, has a
<br />copied certification by Don M. Williams, dated 10/30/80. We assume the 1981 REV. 2 is the
<br />correct version, and that REV. B was replaced and can be discarded. Please advise as to whether
<br />this is in agreement with your permit copy. Also, our copy of REV.2 contains only ahand-written
<br />"Map 32" designation, and as noted the certification is not original. Please provide a properly
<br />labeled and certified Map 32.
<br />20. Maps 43 through 46 are sheets 1 through 4 of "D Portal Area Site Restoration Plan". For Maps
<br />43, 44, and 46, our permit copy contains two versions of each map, REV. C, with a revision date
<br />of 4/23/81, and REV. D, with a revision date of 10/13/81. The primary difference between the
<br />two versions appears to be that REV. C maps depict rock checks as the primary sediment control
<br />measures for the reclaimed D Portal Area, whereas REV. D maps depict incised sediment traps of
<br />specified volume. REV. C maps depict 12 rock checks on reclaimed Scullion channel and
<br />tributaries, whereas REV. D maps depict only three incised sediment traps, all on the main
<br />channel.
<br />Permit text on page V-16 references "loose rock check dams...shown on Maps 43, 44, and 46",
<br />and specifically references 3 such check dams. Three rock checks were indeed constructed during
<br />initial mine construction, downstream from the DP-1 pond embankment. It is possible that there
<br />was a lat@r revision of this map series that restored the loose rock check dam design referenced in
<br />the pennif text. Please review your permit Maps 43, 44 and 46, with respect to revision
<br />designations, revision dates, and sediment control specifications. If you have more recent
<br />revisions of the subject maps, or if you can otherwise clarify the apparent discrepancies, please
<br />advise. If the Revision D maps dated 10/13/81 represent the approved plan, then either the map
<br />design or the permit text, or both, will need to be amended to correspond.
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