2009-09-11_APPLICATION CORRESPONDENCE - C2009087

• Permit No: C2009087
• IBM Index Class Name: Application Correspondence
• Doc Date: 9/11/2009
• Doc Name: Additional Preliminary Adequacy Review Comments 47
• From: DRMS
• To: Peabody Energy Corporation
• Email Name: TAK
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215 C O L O R A D O
Denver, Colorado 80203 D t v t s I o N o f
Phone: [phone] RECLAMATION
FAX: [phone] MINING
September 11, 2009 SAFETY
Mr. Vern Pfannenstiel Bill Ritter, Jr.
Governor
Manager Environmental Services
Harris D. Sherman
Peabody Energy Corporation Executive Director
3001 West Shamrell Boulevard, Suite 110 Ronald W. Cattany
Flagstaff, AZ 86001 Division Director
Natural Resource Trustee
Re: Peabody Sage Creek Mine (C-2009-087)
Additional Preliminary Adequacy Review Comment 47
Dear Mr. Pfannenstiel:
An additional preliminary adequacy review comment is provided below.
Section 2.05.6(6)
47. The next to the last paragraph on page 2.05-3 says: "No longwall mining is
projected for the initial permit term; therefore, no subsidence is anticipated."
Consistent with this statement, subsequent sections of the permit application
relating to hydrologic impacts (2.05.6(3)) and subsidence impacts (2.05.6(6)) do
not address potential subsidence impacts. Rule 2.05.6(6)(b) requires the
application to include a description of the worst possible consequences which
subsidence, if it occurred, could have for structures and renewable resource
lands. This Rule presumes that subsidence will occur and does not eliminate the
need for predicting the worst possible consequences from subsidence in a case
where subsidence appears unlikely. Although the application proposes only
advance room-and-pillar mining that may result in subcritical panel widths,
subsidence can occur in this type of operation due to a variety causes, for
example: pillar failure, floor heave, rock bursts in the workings, intersection of
unexpected faults in the workings, and unexpected sudden inflows of water or
gas into the workings. Pillar failure can be promoted over a long period of time
by fluctuating water levels in the workings that weaken pillars. Please address
potential subsidence impacts as required by Rule 2.05.6(6).
Please contact me if you have any questions.
Sincerely,

Tom Kaldenbach
Environmental Protection Specialist
cc (via email): Dan Hernandez, DRMS
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines