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

~~OCCUNTAIH COAL
• ASubsidiaryofArehwO~~A~ILLC.
West Elk Mine
POBox 591
5174 Highway 133
Somerset, CO 81434
[phone]
Fax [phone]
• 8th paragraph under Streams and Ditches under Inportance of Baseline Landslide and
Rockfal[ Data.
• 10th paragraph under Background on Stream Channels and Hydrology under Streams
under Surface Water Quality Effects.
• Last paragraph under Background on Stream Channels and Hydrology under Streams
under Sutface Water Quality Effects.
• 6th paragraph before Springs/Seeps (counting numbered sentences as one paragraph) under
Analysis oflmpacts to Streams under Streams under Surface Water Quality Effects.
• 2nd paragraph under Conceptual Description ojSubsidence Impacts to Springs under
Springs/Seeps under Surface Water Quality Effects.
• Exhibit 60B.
~92. Response accepted.
93. Original Comment: Exhibit 60B, conclusions section, concludes that no cracks area predicted in the
• ~q~~ Dry Fork alluvium because no cracks occurred in the alluvium in Apache Rocks. Please identify the
subsidence traverses located in any alluvium or alluvial valleys in Apache Rocks.
MCC Response: Revised text.
New Comment: Text changes could not be located. Please specify the location of the changes.
MCC Response; Please see the added text in Sections 5.3 (last two paragraphs) and 11.3 for this
information. As stated, the observation traverses are located in alluvium and colluviums of Deep
Creek and Sylvester Gulch above mined longwall panels 15 and 16 (see Map 1, September 2004
report entitled "Subsidence and Geologic Field Observations: Apache Rocks and Box Canyon
Mining Areas, July Il-IS, 2004").
Paragraph 2 of Conclusion Na. 3 and Section 11.3 (particularly paragraphs 2 through 4) are new
additions that explain the subsidence effects that are expected during the longwall mining beneath
Dry Fork and its tributaries and also Lick Cree% These conclusions are based on observations in the
Apache Rocks and Box Canyon mining areas and in the Bear Creek area above the Somerset Mine
operated by U. S. Steel Corp up to the 1980s.
~G 94. Original Comment: Please explain how subsidence observations from B-seam mining in areas of 1000-
2000 feet of overburden modify or temper conclusions regarding E-seam mining of 14 feet of coal in
areas of 400-500 feet of overburden. Would the expected subsidence impacts be of greater or lesser
magnitude than the B-seam scenario?
MCC Response: MCC addressed tbis in Exhibit 60B.
New Comment: The original question stands. The Division has not been convinced of the conclusions and
predictions can be made as directly for E-seam mining impacts based on B-seam experience.
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