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4. Right of Entry Information for the Mine Area in Appendix 3-4, does not appear to include reference to <br />documents upon which right of entry to portions of the South Extension Area is based. For example, right of <br />entry documentation is apparently not provided for the SE'/a Sec. 27, E'/~ Sec. 34, or the W'/: Sec. 35. Please <br />update Appendix 3-4 as necessary to reference appropriate right of entry documentation. <br />5. Several of the licenses and permits listed in Tab 3, beginning on page 16, have expiration dates that are now <br />passed. Please amend the listing as appropriate to address current status of expired permits and <br />licenses, and list current expiration dates for those permits and licenses that have been renewed or <br />extended. <br />6. Permit Application Tab 4 contains outdated permit acreage references on pages I and l2. Please update the <br />text as appropriate to reflect the currently approved permit acreage. <br />On page 40 of Tab 6 Geology and Overburden Assessment, text indicates that an overburden sampling plan <br />will be implemented in Lennox Coal outcrop areas as shown on Exhibit 6-6, and throughout the southern mine <br />block to identify fmal graded areas having an unsuitable clay, pH, and/or acid base potential level. Sampling <br />and mitigative measures are discussed further in Tab 21 Mtnesoi! Reconstruction. <br />Based on Exhibit 6-6, the spoil sampling plan and associated mitigation as necessary would appear to apply to <br />"D" Pit spoil and highwall reduction areas regraded in 2002. However, [he 2002 Annual Reclamation Report <br />states that "no final grading or revegeta[ion activities occurred in the Lennox Coal outcrop areas during the <br />2002 field season. Therefore, no spoil samples were collected." <br />First, please explain the apparent contradiction between the spoil and highwall sampling area of the <br />"D" Pit as delineated on Exhibit 6-6, and the cited statement in the 2002 Annual Reclamation Report. <br />Unless satisfactory explanation is provided, the approved sampling plan will need to be implemented <br />within [he specified areas of the "D" Pit as soon as possible, and associated data, evaluation, and <br />mitigation plan as appropriate will need to be submitted to the Division by the end of 2004. <br />Second, please note that based on Exhibit 6-6 and text on page 40, spoil sampling would appear to be <br />required in "B" Pit areas to be graded in 2003, and "throughout the southern mine block^ to be graded <br />in future years. Please ensure that this commitment is complied with and that appropriate data and <br />evaluation is included in future annual reclamation reports. <br />8. As referenced in Item 6 above, text on page 40 of Tab 6 commits to implementation of the regraded spoil <br />sampling plan throughout the southern mine block. In addition to potential concerns associated with the <br />Lennox coal and associated strata on page 4Q there is discussion of potential concerns associated with <br />overburden in the proposed Sage Creek/Wolf Creek mining areas, beginning on page 8 of Tab 6. Text <br />indicates that due to limited overburden data from the [I-W Sage Creek/Wolf Creek overburden, suitability <br />assessment included consideration of potential acid forming material associated with the Wolf Creek <br />overburden within the Yoas[ and Seneca 11 Mines. On page 9, the first sentence indicates that "it has been <br />conservatively assumed that the same ABP characteristics could also be present at II-W '. The very next <br />paragraph describes the regraded spoil sampling program that will be conducted immediately after mining, and <br />references Tab 21, Minesoil Recomtruction. A regraded spoil monitoring and mitigation program for Sage <br />11 <br />