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Bowie Resources LLC <br />Permit No. C-1996-083 <br />PR-10 Preliminary Adequacy Review <br />Page 5 of 8 <br />20. The GEI Consultants, Inc. letter of May 22, 2003, Re: Additional Analysis: Geotechnical <br />Evaluation of Mine Induced Seismicity on Bruce Pazk Dam was originally submitted to <br />the Division for Technical Revision No. 22 but never incorporated into the permit <br />application. The Division requests that this letter be added to Volume X Geotechnical <br />Studies Bruce Park Dam. <br />21. Rule 2.05.6(6)(f) requires that the subsidence control plan be "prepared by appropriately <br />qualified professionals". None of the reports in Exhibits 15, 16, 17 or 18 beaz appropriate <br />certifications. In addition, the reports in Exhibits 15 and 18 do not identify who prepazed <br />the reports. Please provide such information. <br />22. Figure 1 on page 4 of the Exhibit 17 report shows a B-seam mine plan that is more <br />extensive than the mine plan proposed on revised Map 14B and Map 27 of PR-10. In <br />order to avoid any confusion, please either revise Figure 1 to only show the mine plan <br />proposed in PR-10 or add a note to Figure 1 that states that the B-seam mine plan <br />approved in PR-10 is shown on Map 14-B and Map 27 of the permit application. <br />23. Under Rule 2.05.6(6)(f)(iv) on revised page 2.05-114, BRL states that the operator will <br />repair any mine-related damage and be responsible for damage to injured parties as it <br />relates to the Bruce Park Reservoir. However, Rule 2.05.6(6)(t)(iv) requires a detailed <br />description of such mitigation plans, as further described in subpazagraphs (A), (B), (C) <br />and (D) of that rule and in Rule 4.20.3. The Division also understands that any work <br />performed on the Bruce Park Dam structures must first be approved by the USDA-Forest <br />Service. Please revise page 2.05-114 and the subsidence handbook in Exhibit 15 to <br />describe in detail the mitigation plan for the Terror Creek Reservoir. <br />24. Under Rule 2.05.6(6)(f)(v)(A) on revised page 2.05-114, it is stated that the pre- <br />subsidence survey for the Tenor Creek Reservoir dam structures can be found in Volume <br />X. However, the information in this volume is quite extensive. Please revise page 2.05- <br />114 to reference the exact reports and page numbers in Volume X that pertain to the pre- <br />subsidence survey mentioned on revised page 2.05-114. The information contained in the <br />pre-subsidence survey must be detailed enough to determine the degree of material <br />damage or diminution of value of the dam structures should it occur. <br />25. On revised page 2.05-117, under Rule 2.05.6(6)(f)(v)(B), mention is made of the seismic <br />monitoring program. However, the purpose of this monitoring program is to measure the <br />strength of the seismic wave at various points, not to measure whether there has been an <br />effect of the seismic wave, or of subsidence for that matter, on the two dam structures. In <br />support of the Rule 2.05.6(6)(f)(v) requirement for a description of the measures to be <br />taken to determine material damage or diminution of value, please propose a monitoring <br />