Laserfiche WebLink
Discussion of Operational Issues Associated with the Alleged Violation: <br />? Unrealistic expectations based on exploration drill hole data. <br />Requiring MCC or any operator to provide a revision to update and provide a mine layout map <br />that precisely shows the length of each projected longwall (LW) panel is not realistic. Mine <br />maps projecting where the economically mineable coal seam ends are drafted based on <br />exploration drill hole data. Due to topography of the surface lands above the coal seams and <br />the considerable cost of drilling multiple exploration holes, it is impractical to space exploration <br />holes at intervals that pinpoint the exact thickness or mineability of the coal seam, and thus <br />determine the exact point to end a LW panel on a map. Exploration holes generally have <br />spacing of several thousand feet which is adequate for determining the estimated extent and <br />quality of the mineable coal reserve, but not adequate for precisely determining the coal seam <br />characteristics (thickness, quality, etc.) at every location within the coal lease. It is impossible <br />to see into and/or through the coal seam to determine where the actual mineable coal exists. <br />The best method of determining if there is adequate coal thickness for LW mining is to develop <br />entries with Continuous Mining (CM) equipment to advance the planned entries (within the <br />lease and permit boundaries) until the coal thickness lessens or coal quality deteriorates to <br />where it is no longer economically feasible to mine. MCC cannot precisely depict the length of <br />LW panels prior to exposing the coal seam with CM equipment. <br />? Projecting the actual extent of a LW panel prior to development mining the perimeter <br />entries of the LW panel is not possible and is unacceptable because the projections <br />would not be based upon reliable data. <br />The length of a LW Panel cannot be accurately determined until the Tailgate, Headgate and <br />Start-line entries have been developed and delineated by CM equipment. Historical mining <br />experience has illustrated that the thickness of coal within the width of a LW panel cannot be <br />accurately determined until the perimeter of the panel has been defined by CM development. <br />This mining experience has repeatedly shown that the variability of the coal thickness within <br />the LW block is such that mine operations projections must be altered based upon the actual <br />coal seam thickness discovered during the CM entry development process. As such, revising <br />the projected mining operations maps and extending a LW panel based on drill hole data or <br />mining data from one side of the panel (tailgate or headgate entries) alone is premature, as <br />well as inaccurate. Delineation of the LW panel perimeter with CM equipment is needed if <br />accurate, exact locations of LW panels must be delineated and mapped. <br />? Unacceptable delays to the development mining process and actual longwall panel <br />delineation <br />MCC does not believe that projected mine operations maps submitted to the Division were <br />intended to precisely depict the final extent of LW panels located within the lease and permit <br />area boundaries. If this expectation were to be enforced as alleged in the NOV, the resulting <br />delays of the mining operations process would be untenable and unacceptable. If MCC <br />reached the end of a LW panel depicted on an approved projected mining operations map and <br />found that the mineable coal thickness in the entries being developed extended beyond the <br />end of that LW panel, according to the regulations as interpreted and alleged to be a violation, <br />9