2011-06-27_REVISION - C1981022 (2)

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Site Construction, Operation and Reclamation The project will be very similar to that which had previously taken place for current borehole sites. Overall, the sites will be accessed via the pre- existing Bear Creek canyon ranch road. New light use road segments will be constructed using sidecast construction techniques, cutting and filling as needed to achieve a typical road width of about 10 - 16 feet. The pad sites will be approximately 150 feet wide and 150 feet long or 0.50 acres. Any salvaged topsoil will be stockpiled adjacent to the pad. Drill fluids will be collected in mud pits. (Approximately, 8'D x 10'W x 40'L in size). After the borehole casing has been completely set, a skid mounted methane fueled pump will be installed over the well head. The pump will be operated with the methane and other gasses drawn from the mine, and any excess gas will be vented into the atmosphere. MSHA has not presently allowed any other suitable alternatives for the vented mine gasses as potential alternatives (such as flaring) could adversely impact miner safety. Unless otherwise requested, the boreholes will be sealed and the new roads and borehole pads reclaimed in accordance with the procedures further described in the PAP or in accordance with the applicable regulations. Typically, a particular GVB site is reclaimed the year after a panel is mined and sealed. Threatened and Endangered Species Assessment, Cultural Resources Assessment A block clearance cultural resources assessment titled "Class III Cultural Resources Inventory of the Block Clearance Area Project" prepared August 26, 2005 by Grand River Institute has previously been submitted to DMG. This proposed GVB project will not effect any areas of concern noted in this report. A "Block Biological Clearance Project" prepared in August 2005 by Monarch and Associates covers the project area. A copy of the reports have previously been forwarded to the Division and can be found in PAP Exhibit 2.04 -E7. The proposed changes for each of the panels 17,18 and 19 are as follows. Panel 17 LW- 17 -04B was formerly approved as a directional borehole located at the LW -17 -04 pad site. It is now is proposed as a vertical borehole from its own padsite. Panel 18 Pilot hole 18 -01 A was drilled. Formerly approved LW 18 -01 A, 01B and 01C were not drilled. The site is no longer needed and will be reclaimed. Borehole LW-18-01B is moved to a new site for a vertical borehole. LW- 18 -02B is a new vertical borehole site with 640' of new road. Old 18 -03 pilot hole pad will now be reclaimed. • Page 2