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Permit Revision Adequacy <br />July 6, 2004 <br />Page 11 of l8 <br />85. The applicant is appazently proposing to remove currently approved permit text dealing with <br />subsidence of the Apache Rocks and Box Canyon azeas. They do comment that subsidence in <br />the Apache Rocks and Box Canyon azeas is addressed in Exhibit 60, which will be retained as <br />part of the approved permit. While to some degree, Exhibit 60 does contain a detailed <br />subsidence analysis done by Richard Dunrud, the DMG does not believe that the content of <br />Exhibit 60 meets the requirements of each of the rules of Rule 2.05.6(6). This is even more <br />important considering that active mining is occurring in Box Canyon right now and will be for <br />the next several years. Please retain the subsidence text from the Apache Rocks and Box <br />Canyon areas so that important information is not lost. <br />86. The applicant does commendable job of presenting information in the order requested by the <br />Rules. However, given the multiple mining areas, multiple coal seams, and the numerous <br />potential consequences to the various structures and renewable resource lands, it is somewhat <br />difficult to determine whether all subsidence consequences, mitigation, and monitoring is <br />adequate and meets the requirements of the Rules. The DMG respectfully suggests that some <br />type of summary and/or table be included under the subsidence section that clearly describes <br />each type of structure or renewable resource, the worst possible consequence of subsidence for <br />each, the subsidence control or mitigation proposed, and the monitoring necessary for each. <br />DMG is willing to discuss any other ideas MCC has to bring this important information into <br />focus. <br />87. The applicant makes mention of an agreement to monitor water resources above the area to be <br />mined (Exhibit 19C, and noted on page 2.04.80). Please include this monitoring in the <br />monitoring plan and indicate that the results will be included in the Annual Hydrology Report. <br />88. On page 2.05-90, third paragraph from the end should read "(and FiQUre 1 of Exhibit 60B)". <br />There is no Map 1 in Exhibit 60B. <br />89. On page 2.05-94, middle of the page, it states "...associated mitigation measures will focus on <br />returned (sic) disturbed urea to a capability and land use(s) which existed prior to mining." <br />What aze these mitigation measures? Any mitigation measures should be cleazly stated in the <br />permit text. <br />90. On page 2.05-97, last sentence, text states "...due to the lack of structures and limited human <br />activity within the permit area..." Please review this statement and revise if necessary, given <br />the Division's understanding of structures as man-made features such as roads, power lines, <br />buildings, tanks, water wells, etc. This also pertains to previous text and interpretation of <br />structures as only buildings identified buildings in the SOD azea. Please amend the text. <br />91. On page 2.05-100, middle of the page, the text states "The areas with overburden less than 400 <br />feet include the western reaches of longwall panels E2-E5. The minimum overburden thickness <br />above mining in the South of Divide permit revision area is 400 feet." These two sentences aze <br />contradictory. Please correct as necessary. <br />92. On page 2.04-61, proposed text states "overburden is typically greater than 1000 feet for the B <br />and E seam in Apache Rocks and SOD." However, E seam overburden is less than 1000 feet in <br />