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2017-02-15_REVISION - C1981041
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2017-02-15_REVISION - C1981041
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Last modified
2/16/2017 6:57:50 AM
Creation date
2/16/2017 6:44:22 AM
Metadata
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Template:
DRMS Permit Index
Permit No
C1981041
IBM Index Class Name
Revision
Doc Date
2/15/2017
Doc Name
Comments to Proposed Decision Approving Snowcap Repair Plan
From
James A Beckwith
To
DRMS
Type & Sequence
TR69
Email Name
JHB
JRS
Media Type
D
Archive
No
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JAMES A. BECKWITH <br />LETTER TO JAMES R. STARK, DRMS / COMMENTS TO PROPOSED DECISION ON SNOWCAP REPAIR PLAN / PG. 7 <br />testing, and further employed Huddleston -Berry Engineering & Testing (HBET) to review and <br />provide oversight of Fugro's testing. <br />Snowcap dumped 10,000 gallons of water into the 18" x 18" ferrel ditch dug by <br />Fontanari. The water disappeared down the sinkhole so quickly that water did not overflow the <br />ditch. HBET denied that a cavern 100 ft. below the surface could cause surface subsidence <br />depressions and sinkholes. Fugro conducted ERT analysis, finding only one vertical, sub -surface <br />anomaly in the vicinity of the Fugro-identified "Air Shaft Location" shown in Figure 14-17 <br />(Fugro; April 28, 2016, Letter; Fig. 2] Notably, Fugro did not find any horizontal sub -surface <br />anomalies, and its readings in the sinkhole and air shaft were conflicting. When the resistivity <br />readings should have been high (assuming the fundamental laws of physics were not violated), <br />they were low. When they should have been low, they were high. Neither Fugro nor HBET <br />could definitively posit a connection between the sinkhole, the air shaft and the sole vertical sub- <br />surface anomaly. <br />Fontanari's critique of the April, 2016, reports by Fugro, HBET and Mr. James Stover <br />(consulting mining engineer) were not favorable. Therefore, in August, 2016, Snowcap directed <br />Fugro, Stover and HBET to again test the same 15 acres is had tested by ERT in April. This time, <br />Snowcap dumped 8,500 gallons of water down the sinkhole in the ferrel ditch: with the same <br />results as in April, 2016 (immediate loss of water). [SEE: Pg. A14-15-6] Snowcap did not test <br />or inspect to determine to determine if these 8,500 gallons entered the collapsed mining cavern. <br />In addition: <br />"Another 2,000 gallons went into the rock pile feature shown below (in Fugro <br />Figure 3) .... Figure 3 shows a backfilled sinkhole immediately west of the buried <br />8 inch non-metallic water line (owned by Ute Water Conservancy District). A <br />metal market post for the water line can be seen in the upper left of the photo." <br />[Appendix 14-15; Pg. A014-15-7,9/16] <br />The 2,000 gallons dumped down the "rock pile sinkhole" shown in Fugro Exhibit 3 <br />"...reached equilibrium, overfilled, and spill(ed) out on to the adjacent ground. The water did <br />not disappear down (the) hole which indicates no hydrologic connectivity....". [Repair Plan; Pg. <br />14-35] Snowcap now quarrels over whether the water was put into the air ventilation shaft or in <br />some other rock pile. The proof is in the pudding: i.e., the Fugro Exhibit 3. That is a photo of <br />the air ventilation shaft due east of the ferrel ditch sinkhole (Fugro Exhibit 4, Pg. 14-9; 9.16) and <br />due west of Ute Water District's PVC water line. It is the same photo of the same feature as <br />shown in Figure 3 of Fugro's April 23, 2016 Report. Moreover, Fontanari Appendix L is a <br />photograph of the air ventilation shaft, showing the tracks of the water truck which delivered the <br />2,500 gallons, and the surface overflow from the air shaft. Moreover, Snowcap clearly <br />acknowledges that the air ventilation shaft was backfilled several years prior to the testing which <br />explains that water will not go down that shaft to the collapsed mining cavern. <br />Fugro Consultants again conducted ERT studies: using the similar land and grid, but with <br />smaller electrode spacings (and thus a reduced area of study). This time, Fugro found two <br />horizontal, sub -surface anomalies located northwesterly of the air ventilation shaft (or "rock pile <br />
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