REV15531

• Permit No: C1981038
• IBM Index Class Name: Revision
• Doc Date: 6/20/2003
• Doc Name: Adequacy Review
• From: DMG
• To: J.E. Stover & Associates
• Type & Sequence: RN4
• Media Type: D
• Archive: No

d. In the submittal dated January 23, 2003, a revised Figure 2.05-t% entitled
"Permanent Mine Seals" was submitted. However, the information in the
revised figure is not the same information found in the approved mine sealing
plan. The approved mine sealing plan is shown in Figure 2.05-6 in the Final
Abandonment Tab of Volume 6A and further described on pages 77 and 78 of
Section 2.05.4 of the permit application. In the approved plan, portals are to
have a seal of concrete blocks ar similar type material, and then backfilled
with at least 25 feet of incombustible material. Revised Figure 2.05-6 shows
two plans, one that involves only backfilling and a second with about 100 feet
of backfilling in front of a concrete seal. Please explain why Figure 2.05-6
was revised.
Also, there is a note on the revised Figure 2.05-6 that states that the East
Portals have not been backfilled with incombustible material as December of
2002. However, field inspection shows that this incombustible material has
been present for at least a year. If you agree, please revise this note to reflect
the current situation.
Finally, please clam the method used to backftl! the East Mine portals and
the West Mine portals. The note on revised Figure 2.05-6 mentions that the
portals are backfilled seals, but it is not clear to the Division whether or not
this backfilling includes a concrete seal, or concrete blocks, as approved in
the permit.
The Division has no further concerns. BRL stated in the submittal dated May
I5, 2003 that the reclaimed West Mine portals have concrete block seals with
50 feet of noncombustible material. The East Mine portals were sealed with
50 feet of noncombustible material and no concrete block seals. Figure 2.05-6
was revised in the submittal dated May 15, 2003.
The Division is in the process of updating the reclamation cost estimate for the Bowie No.
1 Mine. When the cost estimate review is finished, the Division will forward the estimate
to BRL for BRL 's review.
As a note, the Division's reclamation cost estimate for Permit Renewal No. 4 will include
the reclamation cost for the Bowie No. 1 train loadout. This is because the final approval
of the transfer of the Bowie No. 1 train loadout to the Bowie No. 2 permit is contingent
on Bowie No. 2 increasing the reclamation bond to cover the reclamation costs of the
train loadout. Until Bowie No. 2 increases the reclamation bond appropriately, the
Bowie No. 1 train loadout remains with the Bowie No. 1 permit. Also, since the transfer
of the Bowie No. 1 train loadout has not been finalized, BRL does have the option of
withdrawing the transfer approval and, thereby, not having to amend the bond
documents.