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J. E. STOVER & ASSOCIATES, INC. <br />P.O. BOX 60340 <br />GRAND JUNCTION, COLORADO 81506 <br />PHONE: (970) 245-4101, FAX 242-7908 <br />MINE ENGINEERING CIVIL ENGINEERING <br />MINE RECLAMATION CONST. MANAGEMENT <br />June 11, 2009 JUN 15 2009 <br />J. J. Dudash Dive,,,. . -nation, <br />Division of Reclamation, Mining & Safety Mining and Safety <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />RE: Bowie No. 2 Mine, Permit No. C-96-083, Bowie Resources LLC <br />Technical Revision No. 64, Coal Refuse Pile Slope Inclination, Adequacy Review <br />Dear Mr. Dudash: <br />The DRMS' letter dated June 1, 2009, transmitted its adequacy comments regarding the <br />referenced technical revision. Following are Bowie Resources responses to the DRMS' <br />comments and concerns: <br />DRMS: <br />Geotechnical Review <br />The application for TR-61 was prepared to update the permit application package to reflect a <br />steepened slope configuration for Coal Mine Waste Disposal Area #2 (CMWDA2) that was <br />previously approved under TR-56. With TR-56, the operator successfully demonstrated [in a <br />report prepared by Buckhom Geotech, Inc. (BG1)] that slopes as steep as 3H: 1 V for the upper <br />portions of CMWDA2 will provide a Factor of Safety of 1.50 when proper methods of <br />construction are used and site conditions are periodically monitored. <br />In its review for TR-56, the Division listed several items that the upcoming technical revision <br />application (TR-61) would be expected to address. Those items are each repeated below ("OC", <br />for "Original Comment"), followed by an evaluation of the current TR-61 application ("NC", for <br />"New Comment"). <br />Vibrating Wire Piezometers <br />OC: Five instruments were originally installed in four separate holes in 2005; two of the <br />piezometers (in two holes) later ceased to function. Pore pressure data from the remaining three <br />piezometers were utilized to develop assumptions for use in the stability evaluation. In Section <br />6.0 (Page 14 of 15), BGI recommends on-going monitoring of piezometers as construction of <br />CMWDA2 progresses. <br />Please describe the proposed on-going piezometric monitoring plan, including the locatipns of <br />any new piezometers to be placed, any anticipated modification of existing piezometers, and the <br />proposed monitoring frequency. <br />NC: Page 14 of the Volume IX text in the application states, in essence, that quarterly inspection <br />reports will provide a summary of instrumentation monitoring on CMWDA2, including a <br />discussion of the vibrating wire piezometer data. This data will determine if the measured pore <br />pressures are relatively stable, and consistent with those incorporated into the TR-56 BGI