Laserfiche WebLink
Mr. Roy Karo <br />Seneca Coal Company <br />Apri128, 2004 <br />Page 2 <br />Page 8 of Tab 19 indicates that the azeas of land that will be disturbed through the five-year <br />permit term are shown on Exhibit 20-1. As indicated in Tab 20 of the permit document Exhibit <br />20-1, 5-year disturbance boundary has been superceded by Exhibit 12-1, Operations Plan (Sheet <br />2 of 2). Please revise the reference to Exhibit 20-1 accordingly. <br />Please revise Tab 25 to include an updated table showing current open pits and ungraded azeas <br />associated with worse case disturbance. Please also review and revise the Bond Cost Worksheets <br />contained in Attachment 25-1 if necessary. SCC should provide the Division with an updated <br />estimate of worse case disturbance. Based on estimates from our recent site inspection, it <br />appears that SCC is at their worse case disturbance for the current permit term. <br />The Permit Index List of Exhibits needs to be updated in Tab 1. Please also ensure that all Table <br />of Contents in all tabs that aze affected by this revision, are appropriately updated. <br />Please remove the reference to Exhibit 19-1 and update Page 9 of Tab 19 with appropriate map <br />references. <br />Please condense the text that is spread out on pages 6, 7, and 8 of Tab 19. If possible this should <br />be condensed onto one or two pages. <br />On Exhibit 19-1 B, the area north of YPM-7 designated 2004 should be shaded green. This area <br />was previously approved as the 2003 variance area. Final grading, topsoil distribution and <br />seeding must occur in 2004 to be consistent with contemporaneous reclamation practices. A <br />portion of this area is included in the 2001-2002 designated area for backfill and grading and is <br />still under a pending cessation order. SCC must complete topsoil redistribution and seeding <br />activities at the 2001-2002 backfilling and grading area shown on Exhibit 19-1A by July 17, <br />2004. The Division has extended the time for abatement 180 days at this location. <br />If necessary, please make appropriate changes/updates to the Operations Plan -Topsoil <br />Removal, Exhibit 12-1A as a result of this technical revision. <br />Has the Highwall Mining Ground Control Plan been approved by MSHA? If this plan has been <br />approved, please provide the Division with this documentation. <br />The Division is concerned that the Highwall Mining Limit as shown on Exhibit 12-1 extends all <br />the way up to the permit boundary in two locations. Any subsidence effects have to be within the <br />permit boundary. SCC must adequately address subsidence effects. Angle of draw effects <br />associated with subsidence should be considered. On page 12-2-3 of Attachment 12-2, SCC <br />addresses Rule 4.23.2(6)(d), subsidence resulting from auger (hghwall miner). The first <br />sentence of this discussion makes reference to the engineering design analysis conducted by <br />