2008-11-26_REVISION - C1996083 ‎(5)‎

• Permit No: C1996083
• IBM Index Class Name: REVISION
• Doc Date: 11/26/2008
• Doc Name: Responses to the DRMS Comments and Concerns
• From: J.E. Stover & Associates, Inc
• To: DRMS
• Type & Sequence: PR11
• Email Name: JJD
• Media Type: D
• Archive: No

J. J. Dudash -2- November 25, 2008
BRL - No response required.
5. DRMS - The Division has reviewed the mine plan change first proposed in PR-10 and,
then, revised further in PRA 1. The change in panel orientation between PRA 0 and PR-
11 will result in a different manifestation of subsidence impacts. However, the application
materials adequately address these impacts and the orientation does not significantly
change any of the predictions or result in new concerns regarding impacts or mitigation.
The Division does not have any new issues as a result of PRA 1 with regard to
subsidence and surface impacts associated with subsidence that have not already been
presented within PR- 10.
BRL - No response required.
6. DRMS - Please update the Probable Hydrologic Consequences section 2.05.6(3) of the
permit application to include a discussion of the hydrologic impacts of the operations
proposed in PR-11.
BRL - Section 2.05.6(3) is currently being updated with TR-57. BRL believes the TR-57
update is applicable to the operations proposed in PR-11.
7. DRMS - In the review of PR-10, the Division requested that BRL develop a mine water
inflow monitoring program, per Rule 2.05.6(3)(b)(iv), since the PR-10 mine plan proposed
limited extraction beneath a portion of Hubbard Creek. However, in PR-11, no such
limited extraction beneath Hubbard Creek is proposed. Therefore, no mine water inflow
monitoring program is needed.
BRL - The commitment to monitor mine inflows in the limited extraction zone beneath
Hubbard Creek was deleted from page 2.05-78.
8. DRMS - In the review of PR-10, the USDA-Forest Service approved BRL's proposed plan
to longwall under Dove Gulch and Dove Cave. In PR-11, BRL has submitted a new
analysis for Dove Cave since the mine plan has changed. The Division will need
documentation that the USDA-Forest Service approves of these changes.
BRL - Via e-mail to the DRMS, the USDA-FS gave their approval of the Dove Cave
protection plan and Maleki Technologies, Inc., December 2007 report.
9. DRMS - On proposed permit application page 2.05-119, a monitoring program to confirm
the angle of draw at the end of panel B-11 is described. The next paragraph states that
the results of the subsidence monitoring program will be submitted semi-annually.
Because of the proximity of the Bruce Park Dam and Terror Creek Reservoir to panel B-
11, please revise the text to show that the results of the subsidence monitoring program
in that area will be submitted more frequently.
BRL - The commitment to perform monitoring to confirm the angle of draw on the edge
of B-11 panel is now on page 2.05-121. A commitment to submit the results more
frequently was added to page 2.05-122.
10. DRMS - There are three locations in the permit application text where the words "panels
B- 12 and B-13" should be changed to "panel B-11." The first is on page 2.05-108 and