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~~OUNTAIN COAL <br />~ ~ ~ COMPANY~.~- west E>k Mme <br />A Subsidiary ofP.rch Western Resources, LLC P O Box 591 <br />5174 Highway 133 <br />Somerset, CO 81434 <br />(970) 929-5015 <br />Fax (970) 929-5595 <br />jor the South of Divide Mining Area". Additionally, MCC has reviewed the "Skyline Mine <br />Subsidence Study, Changes in Stream Channel Characteristics and Hydraulic Parameters Related to <br />Surface Subsidence"prepared by the Forestry Sciences Laboratory, Rocky Mountain Research <br />Station in Logan, Utah jor the Monti-LaSal National Forest, Utah in July 1998. This paper <br />addresses the vegetative and geomorphic changes that occurred in the perennial Burnout Canyon <br />Creek as a result ojlongwall coal extraction mining beneath the stream. Further, we have reviewed <br />Burnout Creek flow data collected by the Skyline Mine from 1993 to present to determine what, ij <br />any, effects undermining the stream had on the stream flow volumes. Much ojthe flow data is <br />available from the Monti-LaSal National Forest in the Data Adequacy volumes submitted jor an EIS <br />initiated for the leasing of the Flat Canyon Tract adjacent to the Skyline Mine. Finally, MCC has <br />reviewed the data the Utah Division of Oil, Gas and Mining and the Canyon Fuel Company, LLC <br />have on the effects of longwall mining beneath the perennial East Fork ojBox Canyon Creek, Emery <br />County, Utah by the Sufco Mine. <br />Site Comparison ofDrv Fork and NFRF of Miller Creek <br />As a result ojthis review, MCCfinds significant differences in the general stream morphology when <br />comparing the Dry Fork in the SOD area with the NFRF of Miller Creek in Utah. A striking <br />difference is noted in the overall gradient oJthe portions ojthe drainages affected by mining in <br />• Miller Creek and those to be affected by mining SOD. The portion of the NFRF of Miller Creek <br />undermined had a gradient of 23% while the section ojDry Creek that will be undermined has a <br />gradient 4 %. This difference in gradient is partially responsible for the differences in the amount of <br />alluvia[ cover present in each system. <br />The general cross-section of the two streams is also different. The NFRF of Miller Creek has a fairly <br />narrow channel at the bottom oja steep walled canyon with bedrock forming the majority of the <br />channel floor and colluvium and bedrock forming the channel banks. The majority ojthe Dry Fork <br />channel where there is less than a 1000 feet of overburden above the coal seam to be mine is incised <br />in a thick mantle of alluvium that covers the canyon floor. The stream banks are steep and channel <br />floor and walls are comprised mostly ojsand, silt, and clay with some exposed bedrock. <br />The NFRF ofMil[er Creek has very little alluvial cover in the affected stream channel resulting in <br />the stream ruxxing over large stretches ojexposed bedrock (Erik Petersen, Oral Commuxication, <br />August 20, 2004). Most of the Dry Fork channel floor has a few feet to several feet ojalluvial cover. <br />Specifically, in the areas ojDry Fork where the overburden is 400 to S00 feet thick over the panels to <br />be mined, the alluvium appears to be 10 to 30 feet thick. No discussion is provided in the USGS <br />NFRF of Miller Creek report regarding the thickness of the alluvial cover, if any, on the stream <br />channel floor. <br />The stratigraphy of the NFRF ojMiller Creek is presented only in a general sense. No site-specific <br />lithology is presented to allow the reader to determine what types ojrock units are present in the <br />areas where the creek flow went subsurface. Therefore, it maybe difficult to make meaningful <br />comparisons between the NFRF of Miller Creek response to subsidence and the anticipated effects of <br />subsiding Dry Fork <br />MCC's PR-10 Figure SE Cross Section E-E', illustrates detailed lithology in the area of the west end <br />oJpanels E2 and E3, specifically from drill hole logs of exploration holes SOM-30, SOM-C75, and <br />SOM-57. The logs indicate the presence of claystone and shale beds several tens of feet thick, units <br />15 <br />