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2010-07-02_ENFORCEMENT - C1980007
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2010-07-02_ENFORCEMENT - C1980007
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Last modified
8/24/2016 4:14:39 PM
Creation date
8/5/2010 2:51:05 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1980007
IBM Index Class Name
ENFORCEMENT
Doc Date
7/2/2010
Doc Name
Request to Vacate, analysis and Rebuttal
From
Mountain Coal Company
To
DRMS
Violation No.
CV2010001
Email Name
TAK
Media Type
D
Archive
No
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*anticipated = to imagine or consider something before it happens; foresee; predict <br />1. Affected Area - With respect to underground mining activities? "affected area" <br />means: (i) any water or surface land upon or in which those activities are conducted <br />or located; and (ii) land or water which is located above or below underground mine <br />workin s. <br />2. Underground Mining Activities - means a combination of. (a) Surface operations <br />incident to underground extraction of coal. or in situ processing, such as <br />construction, use, maintenance, and reclamation of roads, above-ground repair <br />areas, storage areas, processing areas, shipping areas, areas upon which are sited <br />support facilities including hoist and ventilating ducts, areas utilized for the disposal <br />and storage of waste, and areas on which materials incident to underground mining <br />operations are placed, <br />By definition in Rule 1.04(86) the permit boundary is to "... circumscribe the permit area ... <br />Permit area includes all areas of land which are or will be affected by surface coal mining <br />and reclamation operations during the term of the permit." As this rule requires and is <br />discussed in detail above, MCC's permit area includes the entire area of leased minable coal <br />reserves within the permit boundary (i.e. all areas ...affected over the estimated total life) as <br />being potentially affected (i.e. affected area). This is documented on the decision forms for <br />both the South of the Divide (PR-10) and Dry Fork lease (PR-12) permit revisions, adding <br />5,250 acres and 1,517 acres, respectively (totaling 6,767 acres) to the permit area, and 4,830 <br />acres and 1,517 acres respectively (totaling 6,347) to the affected area acreages. In addition, <br />the projected mine plan timing and sequencing presented on Map 51 remains unchanged from <br />the discussions in Section 2.05.3 of MCC's permit that approved in the permit prior to the <br />issuance of the violation. MCC did not change its mine layout plan or planned mine <br />sequencing with Minor Revision #MR-365. Minor Revision #MR-365 was submitted by MCC <br />and the Division accepted and approved Minor Revision #MR-365 as abatement of this NOV, <br />even though there was no change to the planned mining shown on Map 51. MR-365 merely <br />added the E seam mining completed at the time of the MR to the existing unchanged mining <br />as had previously been shown and approved on that map. <br />As with the regulations above, no where in this regulation does it state or require that <br />planned and/or proposed mining be specified and/or limited to within the lines, blocks or <br />timing as depicted on a map, MCC's permit boundaries shown on its approved permit maps <br />(including Map 51) envelope the entire area that is leased and that MCC has suggested (i.e. <br />proposed) could be influenced (i.e. affected) by mining over the approximate life of the <br />operation and including the surface operations associated with the underground mining (e.g. <br />MDWs and associated roads, etc.) As such MCC has been and continues to be in compliance <br />with this regulation. <br />? "2.10.30)(k) - Specific Information Requirements - The location and extent of known* <br />workings of active, inactive, or abandoned underground mines including mine openings <br />to the surface within the proposed permit and adjacent areas and the location and <br />extent of existing or previously surface mined areas within the proposed permit area." <br />*known = proved, satisfactorily specified, or completely understood
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