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Mr. Vem Pfannenstiel <br />August 28, 2009 <br />Page 4 <br />acceptable for the Peabody Sage Creek permit. Please incorporate into the <br />PSCM permit application the historic reclamation information pertaining to those <br />lands. The Division will also need one map showing the year each of the <br />reclaimed parcels were seeded and the dates of any inter-seeding or re-seeding <br />that occurred on the parcels. SCCC will need to report reclamation information <br />on the previously reclaimed lands incorporated into the PSCM permit in future <br />Annual Reclamation reports until those reclaimed lands have received final bond <br />release. <br />Section 2.05.3 <br />17. To be consistent with the definition of "affected area" in Rule 1.04(7), please add <br />to the description of the affected area in the next to the last paragraph on page <br />2.05-9 the following two items: the life-of-mine undermined area and the area <br />within the trace of the angle-of-draw on the land surface. Also, please ensure <br />that elsewhere in the permit application other references to the affected area or <br />depictions of the affected area conform to the definition in 1.04(7). <br />18. The application describes the possibility of longwall mining and states that <br />longwall mining will not occur during the first 5-year permit term. The Division <br />is unable to approve an application that suggests the possibility of longwall <br />mining without containing the information required by the statutes and <br />regulations describing the longwall operation and anticipated impacts from <br />longwall mining subsidence. We therefore request the information required by <br />Rules 2.05.2(1), 2.05.3(1), 2.05.3(2)(b), 2.05.6(3), 2.05.6(6), and 2.10 for the <br />longwall operation. <br />19. During the DRMS visit to the Sage Creek site on August 13, 2009, a few <br />locations were found where it is not practicable to treat runoff that will cross the <br />Seneca Il Mine/Sage Creek Mine permit boundary. These locations may need to <br />be designated as "small area exemptions" under Rule 4.05.2(3). These small <br />area exemptions should be permitted as Technical Revisions to the Seneca Il <br />Mine permit prior to the transfer of lands to the Sage Creek Mine permit area. <br />20. Please add to the discussion of blasting signs on page 2.05-30 that signs will also <br />be placed at mine entrances (as required by 4.02(3)). <br />21. So that we may complete our preliminary adequacy review of the operating plan, <br />sediment control plan, and reclamation plan, please provide maps and text that <br />reflect the changes to the proposed surface facilities that were mentioned in the <br />meeting between DRMS and SCCC staff on August 13, 2009. <br />Section 2.05.3(5) <br />22. Section 2.05.3 of the permit application (p. 2.05-28) explains there will be one <br />topsoil stockpile, SCM-001, located south of the proposed coal stockpile, <br />consisting of 165,000 cubic yards of salvaged topsoil. Section 2.05.4(2)(d)