Laserfiche WebLink
Mr. E. Peter Mattheis - 4 - April 27, 1990 <br />Rule 2.05.3(9) <br />This rule concerns the underground disposal of coal mine waste, and requires <br />that the plan be approvable by MSHA as well as by the Division. No evidence <br />is given that this is the case. Additionally, the application is vague as to <br />how underground disposal will be accomplished, citing two possible options. <br />Almost no technical description of the second option is given. Prior to <br />Division approval of the Revision, both alternative disposal options must be <br />shown to be approvable by MSHA. <br />Rule 2.05.4(2)(b) - Reclamation Cost Estimates <br />Current letters from landowners concerning retention of roads are required. A <br />map or maps showing all roads (including exploration) and the portions to be <br />retained also are needed. Costs should operator profit, mobilization, <br />insurance, and performance bond. <br />Rule 2.05.4(2)(c) <br />Cross-sections corresponding to post-mining contours show the mine bench areas <br />not regraded to approximate original contour. This conflicts with a statement <br />in Section 4.4.3.3 of the application, and with Rule 4.14.2(1). Accurate <br />post-mining cross-sections of the benches must be submitted, which will <br />demonstrate that back filling and grading conform to AOC. <br />Rule 2.05.4(2)(d) - Topsoil <br />On page 4-47, NCEC commits to reapply 16 inches of topsoil over the disturbed <br />area, yet on page 3-59 it is stated that 12 inches will be distributed. The <br />approximately 42,500 cubic yards of topsoil currently stockpiled is sufficient <br />to cover almost 20 acres with 16 inches, yet the application states that there <br />will be 47 acres of disturbance. The actual area to be disturbed, the amount <br />to be applied, and the true stockpiled volume, must be determined prior to <br />approval in order to assess whether NCEC is able to meet the redistribution <br />requirements. <br />Rule 2.05.4(2)(9) <br />No plan for the sealing of monitoring wells is provided. <br />Rule 2.05.6(3) <br />The Probable Hydrologic Consequences section (Rule 2.05.6(3)(b)(iii)) of the <br />application does not discuss possible impacts of underground disposal of coal <br />processing waste. At a minimum, the potential impact to quality of ground <br />water in the Wheeler Coal must be evaluated and discussed. <br />