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RULE 2 - PERMITS <br />. 2.05.6 (6) Subsidence Survey, Monitoring, and Control Plan <br />During the initial permit term, PSCM will construct the mine portals and related surface <br />facilities and begin development of the underground mine. Mining will consist of extending <br />the main entries underground and developing up to three continuous miner panels. No pillar <br />extraction or longwall mining is projected. Therefore no subsidence is anticipated. An <br />evaluation of the worst case subsidence potential was conducted by SubTerra, Inc and is <br />shown in Exhibit 2.05.6 -E1. This evaluation considers the potential for 1) mine roof failure; <br />2) pillar failure; 3) pillar punching; 4) unexpected faults; and 5) encounters of gas and water <br />inflows. The evaluation of the worst case conditions predicts that subsidence will not occur. <br />This prediction is supported by the mining history at Twentymile's Foidel Creek Mine with a <br />25 year record of mining. Main entries and continuous miner sections have been developed <br />under similar resources, as identified below, with no measurable subsidence occurring. The <br />mine development has been through faults, under creek areas and in depths that exceed those <br />that will be encountered at PSCM. Water inflows encountered at the Foidel Creek Mine have <br />shown to have no effect on pillar stability. No gas inflows have occurred that would cause <br />any pillar or roof instability. Pillar punching around a longwall extraction can cause floor <br />heave and degradation of the immediate roof but does not in itself lead to subsidence. <br />The publications, What is Mine Subsidence (Exhibit 2.05.6 -E2) and Illustrated Effects of <br />Mine Subsidence (Exhibit 2.05.6 -E3), both from the Pennsylvania Department of <br />Environmental Protection, are used as references for this subsidence evaluation. <br />• The structures and the renewable resource lands identified in the area above the mine works <br />are as follows: <br />1. Grassy Creek, a perennial drainage. <br />2. Little Grassy Creek, an intermittent drainage. <br />3. County Road 27 <br />4. 135 and 340 KV power lines <br />5. 69 KV power line. <br />In reviewing the location of the identified structures, it is recognized that the greatest <br />potential for damage can occur at shallow depths and when coal extractions are high, <br />exceeding 60 %. Grassy Creek, County Road 27 and the 135 and 340 KV power lines are <br />located in areas of the mine that exceed 600 feet of depth and in areas where extraction ratios <br />will be less than 45 %. Any failures in the underground works will not cause any measurable <br />subsidence at the surface. Subsidence of up to 60 inches, at these depths, has been recorded <br />in longwall areas at the Foidel Creek Mine at areas of county roads, creeks and power lines <br />with no material damage to these structures. County Road 27 and 33 have experienced <br />subsidence with out damage to the road surface. Fish Creek and Foidel Creek have been <br />subsided and the flows have been maintained and with no connection to the mine workings. <br />Power line towers have been subsided and show a small amount of tilt but no damage to the <br />structure or the lines. Therefore, subsidence is highly unlikely to these structures and if it did <br />• occur, in a worst case, would not cause material damage or diminution of reasonably <br />foreseeable use of these structures. <br />PSCM Permit App. 2.05 -103 Revision 04/19/10 <br />