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MOUNTAIN COAL <br />COMPANYL.L.C. <br />A subvde of Am WeMem 94uneno Gmq, LLC <br />February 09, 2011 <br />Mr. Tom Kaldenbach <br />Colorado Division of Reclamation, Mining and Safety <br />Office of Mined Land Reclamation <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />West Elk Mine <br />P.O. Box 591 <br />5174 Highway 133 <br />Somerset, CO 81434 <br />(970) 929 -2200 <br />Fax(970)929 -5050 <br />Re: Mountain Coal Company, LLC, West Elk Mine; Permit No. C- 1980.007; Technical <br />Revision No. TR -124, Addition of Maximum Projected Areal Extent of Potential Mining; <br />Responses to Adequacy Comments <br />Dear Mr. Kaldenbach: <br />Mountain Coal Company, LLC (MCC) provides the following responses to the adequacy comments on <br />Technical Revision No. 124 per your letter of February 04, 2011. The Division's comments are quoted <br />below and are followed by MCC's responses. <br />10. "The 19- degree angle of draw is acceptable. Please update all references in the permit <br />application to reflect this value." <br />MCC has revised Map 51 to reflect the recalculated maximum predicted angle of draw of 19 Exhibit <br />60E text has been changed (see attached) to include the revised predicted range of the E -seam <br />angle of draw. Revised Map 51 was provided to you in person yesterday. <br />11. "The DRMS cannot approve TR -124 without adding to the permit application a commitment to <br />submit along with each semi - annual subsidence report an application for a Minor Revision that <br />updates Map 51 with as -built workings. The need for semi - annual updating of Map 51 has been <br />noted in previous adequacy letters for TR -124 and in an email memo from Dan Hernandez to <br />Kathy Welt, dated August 13, 2010. The need for the commitment is indicated by the following <br />three requirements. <br />a) Information in the permit application must be current. [Rule 2,03.3(1)]. <br />b) The subsidence control plan must include a schedule for the submittal of a detailed plan of the <br />underground workings, as required by Rule 4.20.1(3) [Rule 2.05.6(6)(f)(vii)]. <br />c) At the time of revision to a permit, or for permit renewal, to the extent not previously submitted, <br />the operator shall submit a detailed plan of the underground workings. The plan shall include <br />maps and descriptions, as appropriate, of significant features of the underground mine, <br />including the size, configuration, and approximate location of pillars and entries, extraction <br />ratios, measures taken to prevent or minimize subsidence and related damage, areas of full <br />extraction, and other information requested by the Division for good cause shown. Upon <br />request of the operator, information submitted with the detailed plan may be held confidential, in <br />accordance with Rule 2.07.5(1)(b) [Rule 4.20.1(3)]." <br />Per our response last week, MCC continues to disagree with the Division's application of Rule <br />2.03.2(1) as a basis for requiring MCC to submit a minor revision twice a year to "update' Map 51 <br />with the actual mined E -seam workings. As we'd said, keeping the map current with actual mined <br />workings is an impossible task, because just after the most current mined workings are added to the <br />map, mining that occurs during the next mining shift will cause the map to no longer be "current'. In <br />addition, adding already mined workings to Map 51 does nothing to change the <br />