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Coal Mine Waste <br /> 18. Currently, approximately 11 ,000 yards of coal mine waste material are <br /> stored in a temporary stockpile within the facilities area. Backstowing <br /> of the currently stockpiled waste as originally proposed, and additional <br /> waste which would be generated from mining of the revision area may not <br /> be feasible. An acceptable plan for permanently disposing of the <br /> existing waste and the projected volume of waste material to be produced <br /> in the future will need to be submitted. The plan will need to address <br /> the applicable requirements of Rules 2.05.3(8)(a) and 4.10. <br /> Subsidence Survey, Monitoring and Control <br /> 19. Revised Page 2.05.6(18) identifies Pine Gulch Drainage as a renewable <br /> resource area and states that "to avoid impacting the Pine Gulch Stream, <br /> National King Coal , Inc. has committed to not extracting coal beneath <br /> this drainage." Revised Page 2.05.60 9) indicates that no additional <br /> renewable resource lands would be affected by the Kambe Van Camp leases. <br /> However, based on the proposed location of entries and panels within the <br /> revision area as depicted on Map X-002A, it would appear that coal <br /> extraction is proposed beneath both forks of the Pine Gulch Drainage. <br /> The apparent discrepancy between statements in the text which imply that <br /> Pine Gulch will not be undermined and the conceptual mine plan <br /> (Map X-002A) which indicates that Pine Gulch would be undermined will <br /> need to be resolved. If Pine Gulch will be undermined, additional <br /> information discussed below will need to be addressed unless it can be <br /> demonstrated that Pine Gulch does not meet the "renewable resource land" <br /> definition of Rule 1 .040 10). <br /> 20. Assuming that Pine Gulch Drainage is a renewable resource land and that <br /> portions of the drainage will be undermined, the application will need to <br /> include a description of the worst possible conseouences which <br /> subsidence, if it occurred, could have on the Pine Gulch Drainage <br /> pursuant to Rule 2.05.6(6)(b)(i)(A-C). The evaluation will need to <br /> include a description of the Pine Gulch steam characteristics (ephemeral , <br /> intermittent, perennial , or use for irrigation water transport) and a <br /> determination of whether the water is adjudicated; for what purposes and <br /> in what auantities. Based on the stream characteristics and water uses, <br /> and the minimal amount of overburden cover beneath the gulch, the <br /> evaluation should address the potential magnitude and worst case <br /> conseouences of the surface expression of subsidence in the area. <br /> Depending on the conclusions drawn from the worst case conseouences <br /> evaluation, NKC will need to prepare either a monitoring plan pursuant to <br /> Rule 2.05.6(6)(c) , a subsidence survey as described in Rule 2.05.6(6)(e) , <br /> or a subsidence control plan as described in Section 2.05.6(6)(f) . <br /> 21 . Page 2.05.6(23) was evidently inadvertently left out of the revision <br /> application copies which we received, and will need to be submitted. <br /> -4- <br />