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has been added on page 2.05-8 describing this area. The permit application does not include any <br />longwall mining, therefore subsidence is not expected. However, section 2.05.6(6) addressing <br />subsidence has been revised to evaluate for the "worst case subsidence potential". Included in <br />the information is a subsidence potential evaluation report conducted by SubTerra, Inc. and is <br />included in the PSCM PAP as new Exhibit 2.05.6-E1. All revised and new materials are <br />included in the PAP revision package. <br />18.The application describes the possibility of longwall mining and states that longwall <br />mining will not occur during the first 5-year permit term. The Division is unable to <br />approve an application that suggests the possibility of longwall mining without <br />containing the information required by the statutes and regulations describing the <br />longwall operation and anticipated impacts from longwall mining subsidence. We <br />therefore request the information required by Rules 2.05.2(1), 2.05.3(1), 2.05.3(2)(b), <br />2.05.6(3), 2.05.6(6), and 2.10 for the longwall operation. <br />SCCC Response: Longwall mining is not a consideration in this application. All references to <br />longwall mining have been removed in the PAP. The appropriate revised text pages are included <br />in the revision package for replacement in the PAP document. <br />19.During the DRMS visit to the Sage Creek site on August 13, 2009, a few locations were <br />found where it is not practicable to treat runoff that will cross the Seneca II Mine/Sage <br />Creek Mine permit boundary. These locations may need to be designated as "small area <br />exemptions" under Rule 4.05.2(3). These small area exemptions should be permitted as <br />Technical Revisions to the Seneca II Mine permit prior to the transfer of lands to the <br />Sage Creek Mine permit area. <br />SCCC Response: Following the August 13, 2009 CDRMS site visit, Seneca Coal <br />Company/Sage Creek Coal Company re-located the proposed Seneca II/Peabody Sage Creek <br />Mine permit boundary to eliminate any run-off treatment situations that would cause the <br />potential need for small area exemptions or future oversight difficulties for the CDRMS <br />inspectors. <br />20.Please add to the discussion of blasting signs on page 2.05-30 that signs will also be <br />placed at mine entrances (as required by 4.02(3)). <br />SCCC Response: Page 2.05-30 has been revised to include language that blasting signs will be <br />placed at mine entrances and is included in the revised PAP materials.. <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 reflect the <br />changes to the proposed surface facilities that were mentioned in the meeting between <br />DRMS and SCCC staff on August 13, 2009. <br />SCCC Response: Complete revisions to Section 2.05 Operation and Reclamation Plans, <br />including relevant figures, tables, exhibits, and maps, have been made to address the changes <br />discussed with CDRMS staff regarding PSCM surface facility and mine plan changes as well as <br />those changes necessitated by the CDRMS preliminary adequacy review. These revised <br />materials address the most current operating, sediment control, and reclamation plans in detail. <br />6