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-3- <br />Question No. 1 (continued) <br />'The next question pertained to Mr. Krassa's comments in his Paragraph No. 8, and to the status of our <br />review of the operator's subsidence predictions. <br />Mr. It:assa has requested the operator provide a map showing the pay thickness and lateral extort of <br />the coal seam. 11re operator, however, is not required to provide this information. 'The relevant <br />regulation in the matter regarding a map with coal seam thickness and extent is 2.04.6(3)(a). Neither <br />a map showing the lateral extort of the coal seam nor an isopach map indicating the pay thickness of <br />the coal seam is discussed. Operators may identify coal seam thickness with a erossJsectioa, which <br />Basin has done. <br />'The expected surface extort of potential subsidence effects has been identified by the operator on the <br />'Structure Inventory Map.' this predicted extort of subsidence effects was derived using m angle <br />draw of 30 degrees, as described in the operator's subsidence survey submitted pursuant to <br />Rule 2.05.6(6)(e). Ia addition, a 500-foot buffer mae around the angle of draw Tione has been drawn <br />on that map, and' aB atrtrcttrres within the 500-foot buffer, as well as within the expeetod angle of <br />draw area, were Listed in the structure inventory. Further, the operator, is consultation with <br />Jim Pendleton, has submitted a proposed monitoring program to verify the conclusions of the survey. <br />VYe arc still reviewing these submittals. <br />2. Iksautel's Letter of February 24. 1994 <br />A question was raised as to whether water monitoring in the Rancho Escondido arcs was necesvary given the <br />Division's review of the Goldin lgle Miae PHC sad I~IIA. 'This question concerned Jeff Desautel's <br />comments in Paragraph No. 5 of his February 24, 1994 memo. <br />the answer is the same as the answer regarding Mr. ICrassa's comments in Paragraph No. 6 of his <br />letter of February 25, 1994. <br />3. ICrassa's Letter of Frbruarv 22. 1994 <br />A question was asked regarding the status of the operator's compliance with Rule 2.05.3(2)(6). 11ris was in <br />_rpspopss to Mr. ICrassa's comments in Paragraph No. 4 of his letter of February 22, 1994. <br />Rule 2.05.3(2)(6) requires maps and narrative that describe the proposed surface disturbances <br />associated with the underground mining operation to be submitted with the application. Map 12, <br />'Surface Ihsturbance and Post-Mining Isnd Uses, is being updated by the operator to include two air <br />shafts, several degas wells and their associated roads oa the north side of Highway 12. <br />It is my understanding that Raton West believes that areas of proposed subsidence should be shown <br />on the surface disturbance map. However, the definition of disturbed arcs, Rule 1.04(36), states in <br />part that a disturbed area results from removal of vegetation, topsoil or overburden. 'Therefore, <br />subsidence arses arc not considered disturbed areas, and do not appear to be required to 6e shown on <br />the surface disturbance map. <br />A second question was asked concerning the last paragraph of the February 22, 19941etter from <br />Mr. I{rassa, regarding the status of materials that were to be submitted to the Division on <br />February 21, 1994. <br />'lire answer [o this question is the same as the answer [o the question regarding Mr. Rrassa's <br />comments in Paragraph No. 3 of his February 25, 1994 letter. <br />/em <br />M: \oss\ern\c81013.j d <br />