Laserfiche WebLink
iii iiiiiiiiiiiii iiil <br />Dan sss 1~~~/0 l <br />To: Berry, David <br />Subject: roadside subsidence monitoring <br />I received the annual subsidence monitoring report for Roadside today. Everything looks copacetic with the report as far <br />as I can tell. I'll be sending a copy over, and you may want to have someone with some subsidence expertise look it over. <br />I do have a policy question though. <br />The monitoring plan as it is written in the approved permit, requires a twice a year visual survey "over the next years' <br />mining projections and over the past two years of actual mining" and semi-annual survey monitoring of subsidence <br />monuments along Jerry Creek and Coal Creek "twice a year for two years subsequent to undermining". As page 1 of the <br />report states, "There are no mining projections and subsidence monitoring has been pertormed for two years subsequent <br />to mining. Therefore, this is the final annual subsidence report required by the permit until mining resumes at the <br />Roadside North or South Portals." <br />Rule 2.08.4(2)(a) states that a technical revision shall be obtained for "minor permit modifications which meet the criteria of <br />1.04(136). Rule 7.04(136) states, in pertinent parts that "Technical Revision means a minor change...to the terms or <br />requirements of a permit"...and "The term includes...reduction or termination of approved environmental monitoring <br />programs". <br />So my question is this. In this particular case, an environmental monitoring program is being terminated, but the <br />termination was in effect built into the permit, so the permit is not being modified. Does the operator need to submit a <br />technical revision application to allow for termination of the monitoring? Some time back I had recommended to Stover <br />that he submit a TR application for termination along with this years annual report, but he apparently forgot or maybe read <br />the rules and came to a different conclusion. I think a pretty good case could be made for not requiring a revision, but <br />requiring the revision would be the safer course. Do you have a rewmmendation? <br />