APPCOR12443

• Permit No: C1996083
• IBM Index Class Name: Application Correspondence
• Doc Date: 5/31/1996
• Doc Name: BOWIE RESOURCES LIMITED BOWIE 2 MINE FN C-96-083 NEW PERMIT APPLICATION
• From: DMG
• To: J E STOVER & ASSOCIATES
• Media Type: D
• Archive: No

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J.E. Stover & Associates -25- May 31, 1996
Bowie No. 2 Mine
the baseline community is the old "apples and oranges"
comparison; however, at the current time it is the best method we
have. Therefore;
75. The Division proposes that since only one seed mix is being
used for the upland areas, a weighted average method of the
reference areas be utilized for cover and production. Under
this scenario the pre-disturbance acreages should be
carefully documented and those relative values would then be
used to calculate the weight each reference area carries
when conducting bond release sampling.
It may be more appropriate to assign a technical standard at some
point in the future. The Division is currently working on
developing a method to calculate technical standards and when
this becomes available, BRL may want to apply for a revision to
develop a technical standard that will more realistically
represent the reclamation community that is likely to result.
The proposal to not have a woody plant density standard is
acceptable to the Division, however, we have not received
responses back from the CDOW on this issue so it could still be
revisited before a decision on this permit is finalized. In
addition, BRL may want to research the possibility of planting
shrubs in various clumps spread throughout the reclaimed site.
This could be accomplished through drill or broadcast seeding by
simply delineating these areas and planting SHRUB SEED ONLY in
them. This method is a variation of the strip seeding method
that has been successfully employed at some surface mines in
northwest Colorado.
The success standards proposed for the meadow area are acceptable
with the exception of production.
76. BRL should propose a production standard compatible with the
surrounding area and the baseline sampling or provide detail
on why they do not believe that a production standard is not
necessary.
2.05.4(2)(f) Disposal of Debris, Acid-Forming and
Toxic-Forming Materials
As commented in relation to section 2.04.6 (Geology Description)
an inadequate discussion of the acid generating potential of the
Upper B and Upper D coal seams were presented in the text.
Supporting chemical analyses are referenced within Exhibit 6 of
volume III. Page 2-04-18 of the application states; `It is
likely that lime is present in adequate quantities to neutralize
the acid forming component in the coal." The limited geochemical