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Page 16 <br />Rule 2.05.6(6)(f)(v)(A) The results ofpre-subsidence surveys of all structures and surface <br />features which might be materially damaged by subsidence. <br />No formal pre-subsidence survey was found in the application for any structure. None are <br />anticipated for material damage. However, I believe the Dove Cave would suffer material <br />damage if undermined as proposed. <br />There are likely pre-mining surveys of the Bruce Park Dam, both main dam and the saddle dam. <br />They might be available for inclusion in the PAP, even if only by reference. <br />Rule 2.05.6(6)(f)(v)(B) Monitoring, if any, proposed to measure deformations near specified <br />structures or features or otherwise as appropriate for the operation. <br />I conclude that the monitoring program required by the Rules is not adequately prescribed <br />in the PAP. However, there is extensive monitoring being accomplished by the operator, and <br />much of such required monitoring is being accomplished. There is a lot of other monitoring that <br />provides a good understanding of the subsidence at the site. <br />Hydrologic monitoring will continue (revised page 2.05-115). Monitoring of subsidence over <br />Hubbard Creek is proposed (revised page 2.05-115). Monitoring of subsidence over <br />superimposed multi-seam extraction is proposed on page 2.05-115. As mentioned above, <br />monitoring near the Bruce Park Dam is required, and so would it be near the Dove Cave unless <br />long-wall mining is permitted under this feature. <br />The subsidence monitoring program is proposed to extend at least two years beyond cessation of <br />mining in any area, consistent with the need for verification of the subsidence prediction (see <br />revised page 2.05-107). I recommend a summary, as has been developed for water monitoring, <br />identifying purpose, stations, locations, monitoring frequency, and better-defined start and end <br />dates for some activities, and reporting requirements. For example, when (in terms of spatial and <br />time relationships) will monitoring take place for lines 24 through 27 (see page 2.05-115)? <br />Monitoring is to take place quarterly (page 2.05-116) for some items, but not others (photographs <br />every 5 years). The seismic monitoring program at Volume IIIA, Exhibit 18, referenced on <br />revised page 2.05-117, does not address the start, frequency of monitoring and reporting, or <br />termination of seismic monitoring. <br />I am not sure what "mining in any area" means. Hubbard Creek was not protected by a limited <br />extraction zone for D-Seam mining south of Panel D-9 for bleeders and longwall mining. After <br />two years of quarterly monitoring to establish a baseline, I suggest once a year monitoring would <br />be more than enough for Stations 7-A, 7-B, and 7-C until the B-5 Panel headgate has been <br />driven. Quarterly monitoring could then be resumed for Stations 7-A, &-B, and 7-C until work <br />reaches the start of 2 North mains. One more survey could be scheduled at the time of Phase III <br />Bond release for findings concerning affected area.