PERMFILE128862

• Permit No: C1980007
• IBM Index Class Name: Revision
• Doc Date: 6/13/2005
• Doc Name: 2nd Adequacy Response Letter June 2005
• Type & Sequence: PR10
• Media Type: D
• Archive: No

OUNTAIN COAL
COMPANYL.LC. West Elk Mine
. A Subsidiary of Arch Western Resources, LLC P O Box 59l
5174 Highway 133
Somerset, CO 82434
[phone]
Fax [phone]
MCC Response: This information is in Exhibit 52, Adjudicated Water Augmentation Plan. It is
MCC's understanding that CDMG and the State Engineer's Office govern MCC's monitoring.
~~ 88. Response accepted.
~~ 89. Response accepted.
~t,,,90. Original comment: On page 2.05-97, last sentence, text states "...due to the lack of structures and
,~j" limited human activity within the permit area... "Please review this statement and revise if necessary,
given the Division's understanding of structures as man-made features such as roads, power lines,
buildings, tanks, water wells, etc. This also pertains to previous text and interpretation ofstructures as
only buildings identified buildings in the SOD area. Please amend the text.
MCC Response: MCC has revisited this statement and still believes it is appropriate. The text
was amended to include manmade structures and roads. See response to #84 above,
New Comment: The original DMG question remains; no change could be found in the text.
MCC Response: The term "lack of structures" has been replaced by "scarcity ojstructures" to
. reflect the broader interpretation of structures to include roads, etc. A thorough discussion of the
projected effects of subsidence and mine-induced seismic activity on man-made structures and
renewable resources is included in Section 11.0-Effects OjSubsidence And Mine-Induced Seismic
Activity On Man Made Structures And Renewable Resources ojExhibit 60B and the section ojthe
~1 same name in 2.05.6. The man-made structures are shown on Map 67.
~QN 91. Original Comment: On page 2.05-100, middle of the page, the text states "The areas with overburden
less than 400 feet include the western reaches of longwall panels E2-E5. The minimum overburden
thickness above mining in the South of Divide permit revision area is 400 feet. "These two sentences are
contradictory. Please correct as necessary.
MCC Response: MCC revised the text.
New Comment: The original DMG question remains; no change could be found in the text.
MCC Response: The text has been changed at the location described to reflect lowest overburden
thickness of 375 feet along the western reaches of longwa[[panels E2-ES (i.e., 3rd paragraph after
the heading Predicted Subsidence-Related Phenomena and Material Damage Which Would Occur
as a Result ojSubsidence - 2.05.6 (6)(b)(i)(B&C)). Additional text changes were made elsewhere in
the document for consistency with this change. These included:
• 5th paragraph under Apache Rocks and Box Canyon Mining Area under Brief Description
of Mining Method 2.05.6(6)(e)(i)(A) under Subsidence Prediction 2.05.6(rA(e)(i).
• 3rdparagraph under Streams and Ditches under Importance of Baseline Landslide and
Rockfall Data.
• 6th paragraph under Streams and Ditches under Importance of Baseline Landslide and
Rockfall Data.
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