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If we engage this rule, recommend the following adequacy comment; "Please add to paragraph <br />3.1 on page 12-4-2 a statement to the effect that, with reference to the appropriate <br />groundwater analysis of the coal seams, that any drainage would not pose a threat of <br />pollution to surface water from direct discharge, or after commingling with pit <br />groundwater and discharge, to surface drainages. <br />Rule 4.23.2(6) The Division shall prohibit auger mining, if it determines that: <br />Rule 4.23.2(6)(a) Adverse water quality impacts cannot be prevented or corrected; <br />With a reference to coal seam water quality included in the PAP as suggested above, the Division <br />can make a finding that there are no adverse quality impacts. <br />Rule 4.23.2(6)(b) Fill stability cannot be achieved; <br />Fill stability would be achieved. All the fill is part of backfilled pits. <br />Rule 4.23.2(6)(c) The prohibition is necessary to maximize the utilization, recoverability or <br />conservation of the solid fuel resources; or <br />The proposal maximizes the utilization, recovery and conservation of solid fuel resources. <br />Rule 4.231(6)(d) Subsidence resulting from auger mining may disturb or damage powerlines, <br />buildings, or other facilities. <br />Subsidence is not expected (page 12-4-1 of the application), but if it does occur, no such damage <br />would result. However, recommend the following adequacy comment: "Please change the <br />sentence, on page 12-4-1, that reads: `If subsidence does occur there no structures that will <br />be highwall mined underneath.' to read `There are no structures on areas overlying, or <br />within a possible subsidence angle of draw of, highwall mining."' <br />Rule 4.23.2(7)(a) Auger mining shall be conducted in accordance with the backfilling and <br />grading requirements of 4.14. <br />Recommend the following adequacy comment: "Please include, under your comments for <br />Rule 4.23.2(7) on page 12-4-1, or under Rule 4.14 of the PAP, a description of any waiver <br />you require to the 180-day rough backfilling and grading of pit areas used for access for <br />highwall mining." <br />Rule 4.23.2(7)(b) Where auger mining operations affect previously mined areas that were not <br />reclaimed to the standards of these rules and the volume of all reasonably available spoil is <br />demonstrated in writing to the Division to be insufficient to completely backfill the highwall, the <br />