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Twenrymile Coal Company - Foide! Creek Mine, TR06-44 TA Responses 8/!2/2004 <br />Item 55. Page 2.05-106. The construction plan and drawings of Items 45 and 54 may <br />require Mine Safety and Health Administration (MSHA) approval. Please provide this <br />approval inappropriate (Rule 2.03.10). <br />Response: As part of the required MSHA safety review, approval, and training processes, <br />ventilation plan changes relating to construction and operation of the new ventilation shaft <br />and plans for shaft collaring, shaft construction, undergound tie-ins, and ancillary <br />operations (blasting, ground control, contractor training, etc.) will be submitted to MSHA. <br />The required MSHA approvals must be obtained prior to initiating shaft construction <br />activities. Submittal of MSHA plans and approvals is not required under the referenced <br />Rule (2.03.10) and would represent a duplication of effort and jurisdiction. MSHA <br />compliance is addressed through documentation of an active MSHA I.D. number as <br />provided under Rules 2.03.4(4)(a) and 2.03.4(8), and 2.03.10. <br />Item 56. Page 2.05-106, line 28. "Off site " as used in the disposal of materials means "off <br />the permit area ". Should Twentymile want to dispose of inert materials in disposal pits <br />constructed within the permit boundary, or in the coal mine waste pile, please revise <br />accordinely. <br />Resnonse: Please refer to previous response to Item 43 <br />Item 57. Page 2.05-106, line 29. Disturbed grounds need to be restored to approximate <br />original contour [Rule 4.14.1(2)(a)J. Please change so much that reads "will be regraded <br />to reestablish effective drainage and blend with the surrounding terrain. " to read "will be <br />regarded to approximate original contour, to reestablish e, jfective drainage, and to blend <br />with the surrounding terrain. " <br />Response: The text has been revised consistent with AOC requirements. <br />Item 58. Page 2.05-106, line 36. Please add a PAP reference to the pastureland seed mix. <br />Response: The text has been revised to add the requested reference. <br />Item 59. Page 2.05-106.1. Comment. In addition to chisel plow and contour furrows as <br />proposed, experience in reclamation within Colorado has demonstrated that the use of <br />intensive divots and gouges has greatly reduced surface erosion and enhanced revegetative <br />cover and diversity. Twentymile may want to consider inclusion of this procedure in the <br />reclamation plan. <br />Resnonse: Given both the limited disturbance and the relatively flat terrain, our typical <br />reclamation practices should meet the desired reclamation objectives. TCC does, however, <br />recognize the value of surface "pitting", as has been practiced in Utah and other states for a <br />number of years, in limiting erosion, aiding in moisture capture and retention, creating <br />micro-ecological niches, and enhancing overall reclamation. For larger reclamation <br />projects in the future, we anticipate incorporating this technique to optimize reclamation <br />results. <br />