2008-06-12_REVISION - C1996083

• Permit No: C1996083
• IBM Index Class Name: REVISION
• Doc Date: 6/12/2008
• Doc Name: 4th Adequacy Review
• From: DRMS
• To: Bowie Resources, LLC
• Type & Sequence: PR10
• Media Type: D
• Archive: No

pages for Exhibits 15, 16, 17 and 18.
22. Figure I on page 4 of the Exhibit 17 report shows a B-seam mine plan that is more extensive than
the mine plan proposed on revised Map 14B and Map 27 of PR-10. In order to avoid any
confusion, please either revise Figure 1 to only show the mine plan proposed in PR-10 or add a
note to Figure 1 that states that the B-seam mine plan approved in PR-10 is shown on Map 14-B
and Map 27 of the permit application.
The Division has no further concerns. Figure 1 in the December 28, 2006 submittal was revised to
contain the appropriate note.
23. Under Rule 2.05.6(6)(1)(iv) on revised page 2.05-114, BRL states that the operator will repair any
mine-related damage and be responsible for damage to injured parties as it relates to the Bruce
Park Reservoir. However, Rule 2.05.6(6)(1) (iv) requires a detailed description of such mitigation
plans, as further described in subparagraphs (A), (B), (C) and (D) of that rule and in Rule 4.20.3.
The Division also understands that any work performed on the Bruce Park Dam structures must
first be approved by the USDA-Forest Service. Please revise page 2.05-114 and the subsidence
handbook in Exhibit 15 to describe in detail the mitigation plan for the Terror Creek Reservoir.
The Division has no further concerns. The seismic and subsidence monitoring program originally
fell under Rule 2.05.6(6)(f) but was shifted to Rule 2.05.6(6)(c) when there was a determination
that no material damage would occur to the Bruce Park Dam and the Terror Creek Reservoir.
However, the Division requested that a contingency subsidence control plan for the Bruce Park
Dam and the Terror Creek Reservoir be included under Rule 2.05.6(6)(f). Therefore, the original
statement that BRL will repair any mine-related damage and be responsible for damage to injured
parties as it relates to the Bruce Park Dam was put back into the permit application under Rule
2.05.6(6)(f)(iv) in the January 30, 2008 submittal. Now that it has been determined that the Bruce
Park landslide could damage the Terror Creek Reservoir, the repair plan stated in Rule
2.05.6(6)(f)(iv), still applies.
In addition, the USDA-Forest Service requested in their letter dated February 22, 2007 that BRL
add a statement on page 2.05-103 concerning the USDA-Forest Service Special Use Authorization
to the Terror Ditch and Reservoir Company for the Bruce Park Dam. The revised page was
provided in the January 30, 2008 submittal. The Division sent a letter dated April 14, 2008 to the
Forest Service requesting an update on the resolution status of their PR-10 issues. In a response
dated April 18, 2008, the Forest Service stated that BRL's responses to their concerns are adequate
and that, provided the PR-10 application is not further modified, they concur with the approval of
PR-10. The USDA-Forest Service letter is attached.
24. Under Rule 2.05.6(6)(0(v)(A) on revised page 2.05-114, it is stated that the pre-subsidence survey
for the Terror Creek Reservoir dam structures can be found in Volume X. However, the
information in this volume is quite extensive. Please revise page 2.05-114 to reference the exact
reports and page numbers in Volume X that pertain to the pre-subsidence survey mentioned on
revised page 2.05-114. The information contained in the pre-subsidence survey must be detailed
enough to determine the degree of material damage or diminution of value of the dam structures
should it occur.
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