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2016-10-27_REVISION - C1981041
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2016-10-27_REVISION - C1981041
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Entry Properties
Last modified
5/3/2017 12:00:39 PM
Creation date
10/27/2016 12:27:21 PM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981041
IBM Index Class Name
Revision
Doc Date
10/27/2016
From
James A. Beckwith Attorney & Councelor at Law
To
DRMS
Type & Sequence
TR69
Email Name
BFB
DIH
Media Type
D
Archive
No
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JAMES A. BECKWITH <br />LETTER TO BROCK BOWLES, CO DRMS / SNOWCAP COAL COMPANY RECLAMATION / PG. 7 <br />testing methods in April were deficient and simply failed to discover the horizontal anomalies. <br />Whichever, Fugro concluded: <br />The ERT survey cannot determine absolutely the cause of the anomalies <br />identified in the data. The presence of an isolated vertical anomaly in a <br />horizontally layered geologic section is significant especially since the location of <br />the anomaly corresponds to sink hole like surface features and is located in the <br />area of a vertical air shaft. The natural flow of groundwater is expected to be <br />primarily horizontal in the geologic section ... which underlies the area. Vertical <br />flow would occur along features that create permeability across horizontal <br />layering such as fracturing. This fracturing would also tend to decrease the bulk <br />resistivity of the rock units particularly if the fractures are filled or at least wetted <br />with groundwater. The vertical shaft ... may also act as a vertical pathway for <br />groundwater depending on how it was sealed. The presence of depressions and <br />sinkholes in the area suggest that vertical failure has occurred in the area." [Plan; <br />Pg. A14-15-9] <br />Once again, Fugro found a connection between collapsed caverns and surface subsidence <br />depressions: i.e., the "vertical failure in the area". HBET did not comment on this conclusion. <br />Yet, in keeping with its unsupported belief that a mine cavern 100 ft. below the surface was too <br />distant to cause surface issues, HBET wrote: <br />"Based upon all the available data, HBET believes that the horizontal anomaly <br />represents the pathway from the sinkhole openings to the old air shaft. The recent <br />survey also identifies a horizontal anomaly north of the air shaft. However, the <br />anomaly does not appear to connect to the air shaft. In addition, no surface <br />sinkhole expression was observed in this area. Although the survey identified two <br />horizontal anomalies, the data did not identify any horizontal anomaly extending <br />from the rock pile feature discussed in the report. 19 As indicated in the referenced <br />Fugro report, water was dumped into this feature and as a result, HBET would <br />have anticipated that any horizontal anomaly extending from this location would <br />be identified during the survey." [Plan; Pgs. A14-15-1 to 15-2] (Emphasis <br />Supplied) <br />The problem is that undisputed and undisputable surface conditions — at least those <br />currently known and identified by Snowcap (there are more) - simply do not support HBET's <br />simplistic conclusion. Ironically, these unsupporting conditions do not come from Fontanari. <br />They are found, instead, in Snowcap's own report! <br />There are three locations of surface holes in Fontanari Tract 71: the irrigation ditch; the <br />air ventilation shaft; and, the "rockpile". None of these surface features have the same <br />appearance. It is important to note that Snowcap's Figure 14-17 clearly plots these three surface <br />hole as separate and distinct from each other. SEE: Appendix J. Unfortunately, after plotting <br />19 The rock pile is shown in Fig. 14-17 of the Plan. It is located SE of the air ventilation shaft. A <br />photograph taken October 23, 2016, is attached as Appendix K. <br />
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