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Creek/Wolf Creek mining areas is also referenced in the fast paragraph on page 28 of Tab 6 <br />Based on the fore-going discussion regarding Tab 6, it is clear [hat the regraded spoil monitoring and <br />mitigation program is to be applied throughout the southem mining block, in both Wadge and Sage <br />Creek/Wolf Creek mining areas. However, the detailed spoil monitoring and mitigation program contained <br />within Tab 21 Minesoil Reconstruction has not been updated to reflect approved Sage Creek/Wolf Creek <br />mining in the southern mining block, and the monitoring program described on pages 3 and 4 of Tab 21 is <br />specific [o "aeeas near the Lennox Coal outcrop shown on Exhibit 6-6". <br />First, please amend the sections of Tab 21 addressing overburden/spoil handling, <br />overburden/nnderburden characteristics, acid and toxic forming materials, regraded spoil monitoring <br />program, unsuitable spoil mitigation plan, compactibility and erodibility, and postmine spoil <br />characteristics, as appropriate to reflect [he expanded southern block mining plans. Please ensure that <br />monitoring and mitigation plan in Tab 21 is consistent with the commitments in Tab 6 (e.g. that the plan <br />will be applied throughout the southern mining block, in both the Wadge and Sage Creek/Wolf Creek <br />mining areas). <br />Second, please ensure that future annual reclamation reports reference the currently approved <br />spoil/highwall reduction area monitoring and mitigation requirements, and include required data and <br />evaluation. <br />9. Table 6-3 presents suitability criteria for pertinent overburden, underburden, and regraded spoil parameters. <br />The Suitable and Unsuitable values listed for Acid-Base Potential (ABP) appeaz to be in error. The table lists <br />suitable material as "less than or equal [0 5" and unsuitable material as "greater than 5". In contrast, Table 6- <br />5.1 in Appendix 6-5 lists suitable ABP values as "geater than -5" and unsuitable ABP values as "less than - <br />5". In other words, the more negative the value, the higher is the potential for acid production. Values more <br />negative than -5 are typically considered "unsuitable" for root zone materials. The concept is clearly explained <br />in the narrative of Tab 17, page 18, under Overburden Characterization, aswell as mthe third paragraph of <br />page 13, Tab 6. <br />Please amend Table 6-3 suitability criteria for acid-base potential to be consistent with Table 6-5.1 of <br />Appendix 6-5. <br />10. In Tab l2, narrative pages I through 5 regarding life of mine and permit area operations is somewhat outdated, <br />due to the focus on mining of the Wadge Coal exclusively. The second paragraph under Operations <br />Description-Permit Area, on page 5, specifically states that "there are currently no plans for recovery of <br />the... Wolf Creek seam in the permit area". This is no longer the case. Please amend the narrative on pages <br />1 through 5 of Tab f2 to accurately reflect life of mine and permit area operational plans. <br />I I. Narrative in [he first paragraph on page 9 of Tab 12 references landowner requests and Division approval of <br />retention of certain facilities for the postmining land use. The Narrative references two sediment ponds and <br />several road segments that are proposed as permanent structures. The Division notes that additional <br />documentation regarding road retention is required by permit Stipulation 32, attached to TR-42, and that <br />additional documentation regarding retention of sediment ponds and stock ponds as permanent impoundments <br />has been requested pursuant to PR-4, currently under review. Please amend the narrative to reflect the <br />current status of the referenced permanent retention requests and approvals. <br />12. The first sentence under Coa! Resource Protection and Conservation on page 9 of Tab 12 erroneously states <br />that "mining at Seneca II-W involves extraction of a single coal seam...". Please update the narrative [o <br />12 <br />