2015-02-24_REVISION - C1981038

• Permit No: C1981038
• IBM Index Class Name: Revision
• Doc Date: 2/24/2015
• Doc Name: 2nd Adequacy Review
• From: DRMS
• To: Bowie Resources, LLC
• Type & Sequence: TR59
• Email Name: MLT
• Email Name: DIH
• Media Type: D
• Archive: No

Basil Bear, BRL
C- 1981 -038 / TR -59 / PAR
14- Jan -2015
Page 2 of 2
as prepared by a PLS. As noted in the cover letter, the net result is that the permit area increased
by 4.2 acres rather than the 1.5 originally planned. This item has been satisfactorily addressed
for Volume 7.
DRMS 01/14: Permit identification signs, in accordance with Rule 4.02, were installed at a
number of new locations at the Loadout in 2014. The wording proposed in 4.02.2 of the permit
text appears to reflect a time when BRL envisioned a transfer of the Loadout to the Bowie No. 2
permit. Please use this opportunity to update Page 4.02 -1 of Volume 7 to reflect the information
provided on the signs that are posted.
DRMS 02/24: Page 4.02 -1 was revised as requested. This item has been satisfactorily
addressed.
4. DRMS 01/14: The WQCD Discharge Permit found in Exhibit 11 of Volume 7 is outdated (Exp.
June 30, 2007). Please take this opportunity to provide the most recent version of the permit, and
the letter granting an administrative extension. Conversely, the permit could be removed from
Volume 7 and replaced with a paragraph directing the reader to the discharge permit's location
elsewhere in the Bowie No. 1 permit volume set.
DRMS 02/24: The Feb. 18 response package provided a single page for placement in Exhibit 11.
The proposed text directs the reader to the BRL offices for the discharge permit, which is not
acceptable. Please revise the text to refer instead to the NPDES Tab of Volume 8A, and submit
a copy of WQCD's administrative extension of the permit for insertion at the front of Volume
8A.
DRMS 01/22: The Division has found that subsurface ownership for permit and adjoining areas
at the Loadout is not specifically addressed in Section 2.03 of Volume 7 — Paonia Loadout. Rule
2.10.3(1)(a) requires that maps be included which show, "All boundaries of lands and names of
present owners of record of those lands, both surface and subsurface, included in or contiguous to
the permit area;" (emphasis added). [This requirement is distinct from that found in 2.03.4(6)
regarding owners of coal to be mined.] Map 1 is entitled "Surface & Subsurface Ownership ", but
according to 2.03.4(7) of the permit (Vol. 7, page 2.03 -7), "no search for private ownership of the
subsurface areas has been performed ". Please update Volume 7 of the permit to address the
question of subsurface ownership at the Loadout in accordance with 2.10.3(1)(a).
DRMS 02/24: Page 2.03 -7 of Volume 7 was revised; the text quoted above was removed. This
item has been satisfactorily addressed.
This concludes the Division's Second Adequacy Review of TR -59. Please contact me with any questions
you may have as you prepare your response.
Best regards,
Marcia L. Talvitie, P.E.
Environmental Protection Specialist
cc: Jim Stover, P.E., J.E. Stover & Associates, Inc.
Dan Hernandez, DRMS