REV105700

• Permit No: C1982057
• IBM Index Class Name: Revision
• Doc Date: 11/10/2003
• Doc Name: Adequacy Review Letter
• From: DMG
• To: Seneca Coal Company
• Type & Sequence: PR4
• Media Type: D
• Archive: No

addition, any superimposed multi-seam mining would require wider undisturbed blocks in
sub-adjacent seams.
Unless the requirement for undisturbed blocks of coal is waived, please revise the
text on page 12-4-1 of the application to address superimposed high-wall mining of
the three seams, to specify widening the areas of undisturbed coal in the Sage
Creek coal seam to 300 feet, and the areas of undisturbed Wolf Creek to 350 feet,
as may apply, with vertical alignment of the centers of the superimposed
undisturbed areas.
Rule 4.23.2(3) states that if the operation involves surface mining activities and angering, the
angering shall follow the surtace coal mining activities in a contemporaneous manner consistent
with the applicable requirements of Rule 4.
The applicant indicates in text that highwall mining will be initiated and completed "as soon as
possible" after the surface coal has been removed. Review of the mine plan schedule depicted
on Exhibit 12-3 and the backfilling and grading schedule depicted on Exhibit 19-1A does appear
to indicate that, once highwall mining operations are initiated, the highwall mining will be closely
coordinated with dragline coal extraction and backfilling. However, lag time prior to initiation of
highwalling operations will result in segments of the ridgeline Wadge Pit mined out in 2001/2002
remaining open through 2005. "Contemporaneous" time frames need to be more clearly defined
in the text, with respect to coordination between dragline mining of final cut pits and highwall
mining, and with respect to pit reclamation in areas of completed highwall extraction.
12. Please address within Tab 19 whether pit backfilling and rough grading will be
completed within 180 days of completion of highwall mining within any particular
pit location. If this is not the case, please define and justify variance time frames
for any specified locations where the lag between completion of highwall
extraction and pit backfilling would exceed 180 days.
13. Also, please clarify in the Tab 19 narrative how closely final pit backfilling
operations will follow dragline coal extraction in the various pit areas, define those
pit locations where backfilling will be delayed by more than 180 days to
accommodate highwall mining, and specify the maximum delay between dragline
extraction and backfilling within the various specified 180 day variance areas.
14. Rule 4.23.2(4)(a) requires that each auger hole discharging water containing
toxic-forming oracid-forming material shall be plugged within 72 hours aRer completion
by bac~lling and compacting non-combustible and impervious material into the hole to a
depth sufficient to form awater--tight seal or the discharge shall be treated commencing
within 72 hours aRer completion to meet applicable effluent limitations and water quality
standards under 4.05.2 until the hole is properly sealed; and
This item is not addressed in the application. Please add to the discussion under
paragraph 3.1 on page 12-42 a statement to the effect that no toxic-forming or