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Mr. Kent Gorham <br />April 25, 2011 <br />Page 2 <br />detailed summary of the probable hydrologic consequences of mining to surface and <br />groundwater quantity and quality. This summary should address the probable; <br />• Impacts to groundwater quantity (both wells and springs) from subsidence; <br />• Impacts of mining to groundwater quality; <br />• Impacts of mine water inflow and subsequent discharge to surface water quality; <br />• Impacts of subsidence to surface water quantity; and <br />• Impacts of mine water consumption to surface water users <br />NECC Response: Sections 2.04.7(3) and 2.05.6(3) have been modified to address this <br />comment. Section 2.04.7(3)2 has been revised to focus on the alternative water supply <br />should contamination or diminution to a source of water with beneficial use occur. The <br />discussion of probable hydrologic impacts in Section 2.05.6(3) was also expanded to be <br />more comprehensive. The reference has been changed to 2.05.6(3) instead of 2.04.7. <br />Text has been added to both Section 2.05.6(3) and Exhibit 8(4) describing probable <br />hydrologic impacts due to mining the Allen and Apache seams as described in TR-56. <br />The discussion of impacts due to subsidence has been expanded as has the discussion of <br />impacts of mining on groundwater quality. Existing text has also been modified for <br />clarity. <br />3. What is the source of water for the residents where undermining in the Allen Seam will <br />occur in the N1/2 of Section 24 T33S R68W? Please include this information as permit <br />text narrative, along with well permit numbers, if appropriate. <br />NECC Response: Text describing water sources for residents in the specified area has <br />been added to Sections 2.04.7 and 2.05.6. <br />Rule 2.05 Operation and Reclamation Plan <br />4. Please revise permit text narrative on page 2.05-3 that clearly states what mining <br />activities are proposed under TR-56. Reference to Map 3 is appropriate. Refer to our <br />comments in the General Discussion section of this letter. Permit text narrative on page <br />2.05-3 is not clear what activities are proposed under TR-56. Portions of the revised text <br />and text in Exhibit 24 seem to indicate subsidence from retreat mining in areas where the <br />Division understands that no retreat mining will occur. It is critical that there is no <br />ambiguity or confusion as to the location of surface areas where subsidence is planned. <br />Please review the submittal in its entirety with regard to this issue. <br />NECC Response: Map 3 has been updated to more accurately depict the proposed <br />mining. Figure 19 (page 2.05-92) has been added with detail of the development only <br />and pillaring areas. Mining with room and pillar without any secondary extraction is <br />planned for the Allen Seam north and northeast of the East Portals. The slope bottom <br />area is constructed in the Apache Seam. Ramps will be built from the Apache down to <br />the Allen Seam. Mining in the Apache Seam will occur south of the slope bottom area. <br />Mains will be driven to the south with mining rooms east off of the mains. The rooms <br />will be constructed only in areas that do not overlay old Allen workings. One room is <br />Agapito Associates, Inc.