Ramaco Resources, LLC Berwind Deep Mine No. 1 Big Sandy Crayfish Protection And Enhancement Plan 1. Introduction The proposed Berwind Deep Mine No. 1 is located in the headwaters of Right Fork of Beech Fork of Dry Fork of the Tug Fork River. There has been extensive mining and mining related disturbance in Right Hand Fork for the last 90+ years, starting in the 1920's up through 2011, pre and post SMCRA. The most recent mining activity was a deep mine in the Squire Jim seam of coal and the operation of the preparation plant, both of which ceased around 2011. 2. Background Mining and related activities have been taking place in Right Fork since the 1920's. The area has been mined extensively and has had significant prior disturbance all along Right Fork. The Berwind Deep Mine No. 1 is proposing to bond 28.75 acres of which 21.56 acres is currently bonded by adjacent permits. Of the 28.75 acres to be bonded approximately 26.75 acres has been previously disturbed by mining activities. 3. Proposed Operation The proposed operation is a deep mine in the Pocahontas No. 3 and 4 seams of coal. The proposed mine will have a face up, temporary overburden storage area, stockpile area, scalp rock disposal area, and haulroads associated with it. The proposed operation will have full factor sediment control provided as required by the WVDEP regulations. Full factor sediment control as defined by the WVDEP is 0.125 ac.ft. of capacity per 1 acre of disturbance. Pond No. 1 will provide full factor sediment control for the mine face up and stockpile areas. Pond No. 1 is proposed to have a pipe discharge along with a T- Skimmer to provided additional measures to keep suspended solids from discharging since this pond will be controlling the areas with the most activity. Pond No. 2 will provide full factor sediment control for the temporary overburden storage area. The temporary overburden storage area will only be active during construction of the mine face up, ±3 months. After the mine face up is complete and all the material placed in the temporary overburden storage area, the storage area will be revegetated and will not be disturbed again until mining operations are complete and the face up is ready to be reclaimed. Material will be removed from the storage area and used to reclaim the mine face up. The material remaining in the temporary spoil storage area will be used to eliminate approximately 1000' of existing highwall. All disturbed areas will then be revegetated according to the approved planting plan. Pond No. 3 will provide full factor sediment control for the scalp rock disposal area. The scalp rock disposal area will not be disturbed all at one time. The scalp rock disposal area will be built from the toe up and with the completion of each lift the completed lift will be seeded and vegetated in accordance with the approved revegetation plan. Sediment control structures will be constructed and certified by a registered professional engineer or a professional surveyor in advance of any other disturbance in the area being controlled by it. Once the sediment control structures have been constructed and certified, they shall be inspected quarterly and repaired/maintained as needed. Sediment control structures will be cleaned upon reaching 60% capacity. By not allowing sediment control structures to exceed 60% capacity it can be assured that proper settling time in the structure is maintained. No test borings or core samples were collected for this application. The Pocahontas No. 3 seam has been mined extensively in this region. Generally the Pocahontas No. 3 seam in this region has had good water quality and there are no water quality issues with discharges. Water analysis from an adjacent Pocahontas No. 3 seam discharge (GW-P3-3) has been collected and submitted in place of Acid Base Accounting Analysis. The adjacent water data collected is considered to be a better indicator of expected water quality in the proposed mine than the analysis of test borings or core samples. The analysis collected shows good water quality in the water discharging from the existing mine works therefore there is not anticipated to be any impact on water quality from the proposed mining. 1 Ramaco Resources, LLC Berwind Deep Mine No. 1 Big Sandy Crayfish Protection And Enhancement Plan The Haulroad will have minimum 80 cu.ft. sumps spaced according to current WVDEP Regulations, 18 sumps, in order to control sediment from the Haulroads. Haulroad No. 1 is the main haulroad that will be traveled on a daily basis after construction of the face-up and temporary overburden storage area is complete. This Haulroad is a currently certified bonded haulroad that has been in use for 90+ years. Baseline water sampling was conducted on Right Fork to establish the current existing water quality. In-stream water sampling will take place bi-monthly during mining through Phase 2 Grade Release of permit after mining to monitor water quality. Sampling will also take place at the proposed outlets bi-monthly during mining for the parameters and limits listed on the NPDES Permit WV1028952 Discharge Limitations and Monitoring Requirement sheets attached after this document. The majority of water in Right Fork is made up of discharges from old mines in the Pocahontas No. 3 and 4 seams. The baseline water chemistry is listed below and the analysis sheets can be found in Section J-3 of the SMA application.  Six samples have been collected at station P3P4-US1, which is located upstream in Right Fork. The average values based on the six analyses are as follows: pH = 7.73, flow = 0.26 acidity = < 2.00, total alkalinity = 231.67, total iron = 0.255, total manganese = 0.042, total suspended solids = 3.17, total dissolved solids = 292.67, sulfate = 31.50 and aluminum = 0.034.  Six samples have been collected at station P3P4-1, which is located upstream in Right Fork just above the confluence with an Unnamed Tributary. The average values based on the six analyses are as follows: pH = 8.09, flow = 0.28 acidity = < 2.00, total alkalinity = 269.33, total iron = 0.152, total manganese = 0.026, total suspended solids = 3.50, total dissolved solids = 274.33, sulfate = 20.17 and aluminum = 0.027.  Six samples have been collected at station P3P4-10, which is located upstream upstream in Right Fork just below the confluence with an Unnamed Tributary. The average values based on the six analyses are as follows: pH = 8.08, flow = 0.33, acidity = < 2.00, total alkalinity = 179.67, total iron = 0.202, total manganese = 0.036, total suspended solids = 3.33, total dissolved solids = 236.00, sulfate = 38.83 and aluminum = 0.039.  Six samples have been collected at station P3P4-11, which is located downstream of the proposed bonded area in Right Fork. The average values based on the six analyses are as follows: pH = 8.10, flow = 0.80, acidity = < 2.00, total alkalinity = 143.33, total iron = 0.147, total manganese = 0.028, total suspended solids = 8.67, total dissolved solids = 208.00, sulfate = 34.33, and aluminum = 0.038.  Six samples have been collected at station GW-P3-3 which is a discharge from abandoned Pocahontas No. 3 Seam works, which is the same seam as the proposed mine, in an Unnamed Tributary of Right Fork. The average values based on the six analysis are as follows: pH = 7.63, flow = 0.08, acidity = < 2.00, total alkalinity = 149.67, total iron = 0.069, total manganese = 0.001, total suspended solids = 3.00, total dissolved solids = 319.67, specific conductance = 529.5, sulfate = 65.83, aluminum = 0.078. Benthic sampling, as assigned under the WV Narrative Water Quality Standards, will be conducted annually at site BAS 1. The results of the baseline benthic macroinvertebrate sampling at site BAS 1 performed July 29, 2015 are attached after this document. The WVSCI score was 65.72, which means it's not in impaired status but within the Gray Zone. The Gray Zone represents a transitional area of status in the WVSCI score because it is susceptible to a variety of factors that are not representative of biological conditions such as flow, time of year, etc. Whole Effluent Toxicity (WET) tests shall be performed on the effluent from Outlet 001 quarterly as required by the NPDES WV1028952 permit. Outlet 001 is a non-precipitation induced outlet. Outlet 002 and 003 are precipitation induced Outlets. In accordance with NPDES permit WV1028952, in the event of a rainfall event equal to or greater than 0.3 inches within a 24 hour period, during each calendar month monitoring will be conducted at Outlet's 002 and 003. In the event a discharge from Outlet's 002 or 003 is sampled, the samples will be analyzed for the parameters listed below; Flow, Specific Conductance, pH, TSS, Settleable Solids, S04, Se, Fe, Mn, Total Al, Dissolved Al, TDS. 2 Ramaco Resources, LLC Berwind Deep Mine No. 1 Big Sandy Crayfish Protection And Enhancement Plan If there are any future exceedances of any water quality criteria including but not limited to total suspended solids at outlets 001, 002, or 003, WET, or if biological assessment station (BAS) sampling indicates any declines, the facility will immediately notify the U.S. Fish and Wildlife Service (Service), and in consultation with the WVDEP and the Service conduct an investigation and take appropriate corrective action to prevent a future exceedance. If results of the investigation indicate an exceedance in water quality, WET, BAS sampling, and/or total suspended solids, the facility will meet and confer with the Service and an evaluation will be made. A detailed report will then be submitted to the West Virginia Field Office within 45 days regarding the investigation and any corrective actions(s) taken to remediate the exceedance. The Drainage Proposal Map and Site Plan showing the locations of sediment control structures, Outlets, and Water Monitoring Sites is located in the Map Section of the SMA application. The baseline water quality data can be found in Section J-3 of the SMA application. Conclusion Based on the drainage and sediment control measures outlined in the SMCRA & NPDES permit requirements the crayfish should be adequately protected. The drainage will go through properly designed and constructed sediment control structures and outlets to ensure that any discharges are in compliance with Total Dissolved Solids. The outlets will be monitored bi-monthly after construction through the life of the permit/structures for any exceedances of water quality criteria. The water quality of the outlets will be reported quarterly through WVDEP EDMR's. If there are any exceedances then an investigation and corrective action if appropriate will take place to prevent further exceedance. 3 Permit No. WV1028952 Page 2 of 16 1. The permittee is authorized to discharge from Outlet Number(s) listed below: 2. EFFL ENT LIMITATIONS AND MONIT RING FRE UENCY: Outlets should be limited and monitored by the permittee as specified below: MONITORING REQUIREMENTS 1 COW L?Min. Dailr- Avg. J?hMax. Dally Unitsj' Measurement Freq. Sample Typef]. - m. . um- 001 37?12'46" l'h1848 Flow 1 'Ouan ,Report Only Report Only Room Only GPM Estimated 81 ?39'57" Outiet' ?E?egin? . 'lfouan/i OISCHARGE LIMITATIONS Number Longitude In Feet CHARACTERISTICS Specific Conductance 1 Cons Report Only JReport?Only _iReport Only Grab 'pH 1 4Com: 5,00 ?9,00 'Std Units. Grab I Alkalinity. Total-V 1 'Conc 'Re?port Only Report Only ?Repon Oriy Grab Total Suspended Solids 1" Conc 'nepon Only 35.00 "moo Grab "Sen?leable Solids 1 Cone TReport Only 'Repon Only 0.50 I See Section} of PermIt' - Grab Calciumeotal (as?Ca)_ I 'Conc Report Only Report Only [Report Only I ?4 Grab Magnesiumfot Mg) I 1 I . 'Conc 'Report Only 'Report Only Report Only MG ?Grab Sodium.Total (as Na) 1 I . 'Conc_3Report Only Report Only. 'Report Only MG Grab Potassium. Total (as K). 1 Cone ?Report Only JReport Only Report Only MGIL Grab Total?Sulfates (as $04) I 1 I TConc Report Only. Report Only 'Report Only MGL Grab . . . . .. . . I . . Selenlum, Total 1 Cone Report Only "Report Only 'Report Only Grab Recoverable Iron. Total (55 Fe) 1 d?Conc Report Only 1054 0.94 MGIL I Grab Manganese. Total (as Mn) I 1 -Conc iReport Only I 2.00 3.47 I MG I Grab AluminumeotaI (as Al) I 1 I Conc -.'Report Only 0.0? 012 MG Grab .Alummum, DIss. (as Al) I Conc rReport-Only Report Only "Report Only Grab 'EnronIc Torr-Cenodaphnia 1 .Conc Report Only 0.82 $1.64 I Quarterly Grab 'Dubia Total DIssolved Solids . 1 I 'Conc Report?Only :Report Only mReport Only (TDS) . Grab (See?3?. ti) 1. The permittee is authorized to discharge from Outlet Number(s) listed below: 2. EFFLUENT LIMITATION AND MONITORING FRE UENCY: Permlt No. WV1028952 3 of16 Page Outlets should be limited and monitored by the permittee as specified below: Outlet Number Effluent Type Latitude Longitude Elevation ln Feet EFFLUENT CHARACTERISTICS Begins Ends Ouanl Conc LIMITATIONS MONITORING REQUIREMENTS Min. Daily I Avg. Max. Daily I Units Measurement Freq. Sample Type 002 37?12'49" 81 ?39'32" 1913 Flow Quan Report Only Report Only Report Only GPM Estimated Specific Conductance Conc Report Only Report Only pH Conc 6.00 Report Only Grab 9.00 Units Grab Total Suspended Solids Conc Report Only 35.00 70.00 MGIL Grab Settleable Solids Conc NIA Total Sulfates (as 804) NIA 0.50 See Section A of Permit Grab Conc Report Only Report Only Report Only Grab Selenium, Total Recoverable Conc Report Only Report Only Report Only Grab Iron, Total (as Fe) Cont: Report Only 1.42 2.46 MGIL Grab Manganese. Total (as Mn) Conc Report Only 2.00 4.00 MGIL Grab Aluminum, Total (as Al) Conc Report Only 3.00 6.00 Grab Aluminum, Diss. (as Al) Conc Report Only Report Only Report Only Grab Total Dissolved Solids (TDS) Conc Report Only Report Only Report Only MGIL Grab (See 3. 4) 1. The permittee Is authorized to discharge from Outlet Numberts) listed below: 2. EFFL ENT LIMITATIONS AND MONITORING FRE UENCY: Outlets should be limited and monitored by the permittee as speci?ed below: Outlet Number 003 Effluent Type LatItude Longitude 37?12'44" 81 ?40 03' (See 3, 4) Elevation EFFLUENT Feet 1 885 CHARACTERISTICS Flow SpeCIfIc Conductance pH Total Suspended Solids Settleable SolIds Total Sutfates (as 804) Selenium, Total Recoverable Iron. Total (as Fe) Manganese. Total (as Mn) AlumInum, Total (as Al) Alurnmum 0155 (as Al) Total Dissolved Solids (TDS) Beglns Ends 1 Ouan 1 Cone 1 Cone 1 Gone 1 Gone 1 Com: 1 Com: 1 Gone 1 Conc 1 Gone 1 Conc 1 Cone Ouan/ Conc Min. Daily Report Only Report Only 6.00 Report Only Report Only Report Only Report Only Report Only Report Only Report Only Report Only DISCHARGE LIMITATIONS Avg. Report Only Report Only NIA 35.00 NIA Report Only Report Only 1 42 2.00 3.00 Report Only Report Only Permit No. Page 4 Max. Dally Report Only UnIts GPM Report Only UMHO CM 9.00 Units 70.00 0.50 Report Only Report Only 2 46 4.00 6.00 Report Only Report Only WV 1 028952 of 16 MONITORING REQUIREMENTS Measurement Freq. Semi See Section A of Permit Sample Type Estimated Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Grab Results of a Benthic Macroinvertebrate Survey For the Berwind Deep Mine No. 1 Attachment C: WQ Lab Sheets True Line, Inc. P.O. Box 85 Thorpe, WV 24888 Phone: (304)448-2116 Fax: (304) 448-2339 Email: trueline1@frontiernet.net Results of a Benthic Macroinvertebrate Survey for the Berwind Deep Mine No. 1 Baseline Benthic Report 1. Results The results of RBP Habitat assessments are presented below, in Table 1. Table 1. RBP Habitat Assessment Values for BAS 1 Station Epifaunal Substrate/ Embeddedness/ Pool Substrate Velocity Depth/Pool Variability Channel Alteration Sediment Deposition Riffle Frequency/ Channel Sinuosity Channel Flow Status Total Bank Stability Total Bank Vegetative Protection Vegetative Zone Total RBP Score BAS 1 Fall 2015 14 13 15 12 16 14 16 14 13 12 139 WVSCI Scores and underlying sub-metrics are presented in Table 2. Table 2. Results of riffle benthic macroinvertebrate sampling at BAS 1. EVENT % 2 Dominant Taxa (Family) % Chironomidae % EPT (Family) HBI (Family) # EPT Taxa (Family) # Total Taxa (Family) WVSCI Narrative Score BAS 1 Fall 2015 71.75 7.17 89.69 4.19 4 10 65.72 Gray Zone BAS 1 WVSCI scores and sub-metrics were indicative of a Gray Zone. Single-grab water quality parameters assayed during benthic sampling are presented in Table 3, below. Results of a Benthic Macroinvertebrate Survey For the Berwind Deep Mine No. 1 Attachment C: WQ Lab Sheets True Line, Inc. P.O. Box 85 Thorpe, WV 24888 Phone: (304)448-2116 Fax: (304) 448-2339 Email: trueline1@frontiernet.net Table 3. Grab sample WQ results for BAS sampling events. Parameter Name Units BAS 1 Fall 2015 pH Temperature Conductivity Alkalinity Sulfates Calcium Dissolved Oxygen Magnesium Potassium Sodium Total Dissolved Solids Flow Standard Units o C umhos mg/L mg/L mg/L mg/L mg/L mg/L mg/L mg/L cfs 8.59 19.9 473 215 217 23.1 6.7 8.30 2.21 76.70 264 0.75