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The 1630 permit revision application, approved last fall, provided a <br />valid determination of an analogous buffer zone width adjoining the <br />divide, in order to assure prevention of impacts south of that divide. <br />This same rationale could be applied to the streams, resulting in buffer <br />zone widths of 560 feet on each side of the alluvial deposits containing <br />the channels. However, this will result in the delineation of tw•o <br />substantial buffer zones.. <br />Correspondence between CVII12D and wECL regarding problans correlating the <br />aerial survey and proposed and approved changes are attached. 1CECC did not <br />receive a copy of Jim Pendleton's internal maro to Susan :~bwry regarding this <br />matter. This correspondence will be added as an addendtm to Exhibit 3.4.3.,E <br />when the adequacy response information is incorporated into the permit <br />docurent. <br />West Elk Coal Carr2any ~.as re-e•+aluated the life of "F" seam mine plan and <br />based on coal heights, quality, and other mineability criteria revised the <br />mine plan accordingly. The result of these changes is a substantial <br />reduction in the areal extent and overall reserve in the "F" seam. This <br />revised plan should better reflect anticipated mining in the "F" seam. <br />ttE~ has revised Exhibit 3.4.4.B.1 to show the subsidence protection method <br />to be used under the Dry Fork of Minnesota Creek and Lick Creek (although it <br />is not thought at this titre that mining will reach the Lick Creek drainage <br />due to mineability criteria, it is included to present a conser•+ative <br />analysis). The subsidence protection plan which is basically a "no <br />extraction" plan , except for a narrow corridor where development only matt <br />entries will cross under the creeks. This plan will be used until subsidence <br />and hydrologic data fran the nnnitoring of panel I5-1W can be utilized to <br />verify a limited extraction plan for the creek zones. <br />The subsidence protection zones are shown on Exhibit 3.4.4.6.1 which is <br />included in an earlier portion of this adequacy response. The subsidence <br />protection zones were derived by finding the slope break line of the valley <br />bottan containing the creek (this would take into account any possible <br />alfu•+ial areas), adding 100 feet to this on both sides of the creek, and then <br />projecting a 20.5 degree angle of draw downward. Tlie area within these <br />boundaries will be areas of zero extraction with the excep*.ion of the <br />development main entries crossing the protection zone. The attached <br />schanatic shows graphically the methodology used to determine the subsidence <br />protection zone. The width of the protection zone varies with depth of <br />overburden. <br />No subsidence will occur within the valley bottan plus l00 feet on either <br />side (the l00 feet is a buffer zone to account for variations in the <br />projected 20.5 degree angle of draw). Secondary or retreat mining will take <br />place up to the boundary of the protection zone shown on Exhibit 3.4.4.D.1. <br />IX-2 <br />