REV99176

• Permit No: C1996083
• IBM Index Class Name: Revision
• Doc Date: 10/23/2001
• Doc Name: Review Letter
• From: Forest Service Paionia Ranger District
• To: Joe Dudash
• Type & Sequence: TR22
• Media Type: D
• Archive: No

u ~'°'~ United States
Department of
Agriculture
Mr. Joe Dudash
Forest ~Paoni~ P.O. Bos 1030
Service Ranger Distric' , ' N Blo Grande Ave.
LPHONE NO. 970-527-413J Paonia, CO 81428
FAX [phone]
File Code: 282Q_q
Date: October T9, 2001
Reclamation Specialist
Colorado Division of Minerals and Geology
1313 Sherman St., Room 215
Denver, CO 80203
Dear Joe,
RECEIVED
OCT 2 3 2001
~i~ision of Minerals and Geology
The Grand Mesa-Uncompahgre-Gunnison National Forest (GMUG) has reviewed Bowie
Resources Limited's (BRL) submittal for Technical Revision 22 (TR-22). This revision involves
adding the geotechnical data report on the Bruce Park (Tenor Reservoir) Dam to the existing
permit:
Under stipulation on the Iron Point Federal Coal Lease (Section 15, (f)(B)), BRL is required to
evaluate the effects ofmining-induced seismicity on the Bruce Park dam. This stipulation
requires that a study be performed to establish baseline conditions, potential mining-induced
seismicity and potential translated effects to the dam. The stipulation requires that this study be
completed prior to any underground mining activity (including subsidence) within one mile of
the reservoir and dam. The stipulation also requires that a seismic monitoring program be
established to locate, measure and quantify any progressive and final effects of underground
mining activities on the reservoir. The monitoring program needs to provide a continuing record
of change over time and an analytical method for location and measurement of a number of
points over the lease area. The lease stipulation also states that the monitoring program be
developed in consultation with the Dam Safety Engineer, Colorado State Engineer's Office,
Division 4 and appropriate affected parties.
In terms of BRL complying with performing a baseline study, the geotechnical report appears to
have fulfilled this requirement. However, the submittals for the proposed change to the mine
permit do not adequately address the remaining requirements of the stipulation. The potential for
mining-induced seismicity and translated effects to the dam have not been addressed. The
stipulation requires that the study be completed prior to ~ mining (including subsidence)
occurring within one mile of the reservoir and dam. Map 27 (dated June 5, 2001) of BRL's
permit shows that subsidence would extend to within 4,400 feet of the dam. What is unclear at
this point is where BRL's current mining activity is in the Iron Point Lease area, and when they
intend to submit the other required information. In addition, the permit submittal does not
describe a seismic monitoring program that would fulfill the requirements of the stipulation.
Three seismic monitoring points are not sufficient for the monitoring, and the permit submittal
lacked a map showing where those points would be located.
The GMUG supports addition of the geotechnical study to BRL's permit as partial fulfillment of
the lease stipulation. However, BRL needs to complete the items noted above in order to obtain
our complete concurrence.
i
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