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<br /> <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br /> <br />Interoffice Memorandum <br /> <br />March 13, 2015 <br /> <br />To: Jason Musick <br />From: Tabetha Lynch <br /> <br />RE: Bowie No. 2 Mine (Permit No. C-1981-012) <br /> TR-99, adequacy review <br /> <br />This memo is a review of the Bowie No. 2 Mine Technical Revision #99, Revise Hydrologic <br />Monitoring Program, submitted to the Division on 24 February 2015. This revision was <br />submitted to address point of compliance monitoring wells and to incorporate changes resulting <br />from the 2014 monitoring well rehabilitation project. Adequacy review items are numbered at <br />the end of this document. <br /> <br />This review took into account materials provided by Bowie in TR-99 as well as the findings of <br />previous revisions submitted to the Division in relation to the Monitoring Program at the mine. <br /> <br />Interoffice memoranda related to previous relevant Permit Revisions provide a narrative as to <br />the development of the groundwater monitoring program at the Bowie 2 mine. <br /> <br />Briefly, as summarized in the PR-14 groundwater review: <br />The HydroGeo report of September 2008, which was incorporated into Volume III, <br />Exhibit 3 of the PAP with the approval of PR-10, analyzed water quality data from the B- <br />seam and from the strata above the B-seam. Although there remain concerns with both <br />the quality and quantity of data on which the analysis was based - which were <br />acknowledged in the report - the Division accepted the conclusions of the report that: (i) <br />the data show little North-South variation in water quality within the permit area; and <br />(ii) there is no reason to expect the water quality to change beyond the permit <br />boundary to the North. <br /> <br />With the approval of PR-11 the Division accepted the demonstration of the hydrologic <br />separation of the Rollins Sandstone from the effects of mining operations and, as a <br />result, concluded that BRL would not be obliged to install deep down-gradient wells to <br />monitor this member. <br /> <br />With the approval of PR-12, up-gradient (CWI-DH-58 and -60) and down-gradient (2010- <br />1B and -1SS) monitoring wells were incorporated into the PAP and the monitoring plan <br />to monitor the B-Seam and the sandstone above the B-Seam in the western mine plan <br />area. A recommendation was made by the Division to incorporate mine inflow <br /> <br />1313 Sherman Street, Room 215, Denver, CO 80203P 303.866.3567 F 303.832.8106 http://mining.state.co.us <br /> <br />John W. Hickenlooper, Governor | Mike King, Executive Director | Virginia Brannon, Director <br />