GENERAL46537

• Permit No: C1980007
• IBM Index Class Name: General Documents
• Doc Date: 3/9/2004
• Doc Name: Midterm Review Findings Document
• Permit Index Doc Type: Findings
• Media Type: D
• Archive: No

Rule 2.05.6 (6)
(1) Please update PAP Volume 11A by consolidating all the information contained therein dating from
the Apache Rocks ("themtal event") drilling to the current degas drilling activity into a single,
coherent description. Maps should be consolidated also, in a manner to be decided by discussion
between MCC and Division personnel. From this point on, new activity should be documented by
revision of this volume and its maps, rather than by simple addition of new material.
An important feature of the update should be a table showing the drillholes and their status. This
table would be updated with each revision that changed the status of the drillholes and sites. The
table (or a sepazate one) should also specify the drillpad and its size and the road lengths that have
been added. These all would be updated as their status changed from active to reclaimed.
(2) Please update the discussion of subsidence found on pages 2.05-152, 153, and within that section of
the permit, based on observations from B-seam mining. This entire section should be updated to
reflect several years of subsidence monitoring. (For example, annual subsidence reports document
swface cracks above panels 12, 13, 13A, 14, and I5, with depths of cover of 1150 to 1350 feet for
panels 13 and 13A, and approximately 1500 feet for panel 14. That section of the pemtit states that
swface cracking is not observed when cover is greater than 600 feet. Also, a landslide is attributed
to subsidence on p. 9 of the December 2002 subsidence report.)
The Division anticipates a coherent and informative discussion on subsidence impacts that
incorporates the observations of ten yeazs of monitoring since the inception of the monitoring
program above longwall mining, including observations on streams, and the coincidence of various
subsidence features with the underlying operational azeas of the mine.
(3) Exhibit 55 (Stream Channel Parameters and Changes Due to Mining Induced Subsidence) contains
predictions of the effects of subsidence on stream channels. Within the analysis, some of the basins
aze evaluated based on the subsidence effects of 2-seam mining, notably on page 7 of that document
and the succeeding tables. Because of the importance of subsidence on the Dry Fork of Minnesota
Creek and its tributaries, a revised analysis should be provided to account for the current plan for
mining the azea within the watersheds in the "south of divide" azea since two-seam mining is no
longer planned.
4.07.3
The Division has developed a recommended procedure for permanent sealing of methane degas
drillholes. It is requested that Mountain Coal Company adopt the procedwes therein for use when
abandoning degas wells and that this procedwe be included within the 2004 annual operating plan
for the degas program.
SECTION V -RECLAMATION LIABILITY
Pwsuant to Rule 3.02.2(4) the Division conducted a complete review of the reclamation liability for
the West Ells Mine w February 2004, as part of the midterm review. Currently the Division holds a
bond for $10,000,000 for the West Elk Mine. The estimate for the mine, updated for current costs, is
$11, 085, 357. This represents an increase of $1,085,357.00,
Mountain Coal Company must submit the additional bond to the Division within 60 days of the
receipt of this letter.
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