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2015-06-25_REVISION - C1996083
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2015-06-25_REVISION - C1996083
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Entry Properties
Last modified
8/24/2016 6:08:42 PM
Creation date
6/25/2015 10:49:06 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
C1996083
IBM Index Class Name
Revision
Doc Date
6/25/2015
Doc Name
Preliminary Adequacy Review Letter
From
DRMS
To
Bowie Resources, LLC
Type & Sequence
TR103
Email Name
JDM
DIH
Media Type
D
Archive
No
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Bowie Resources, LLC <br />Page 2 <br />6/24/2015 <br />DH -38 respectfully, to serve as upgradiant groundwater wells for the Upper D -Seam or if BRL <br />requests to have these wells terminated from the required monitoring plan, please provide <br />information that will serve as justification for no longer monitoring sites DH -25 and DH -38 for <br />field parameters and full sample suite. <br />According to approved page 2.05-133i, site TC -03-01(B) is completed in the Upper B -Seam and <br />TC -03-02 is completed in the water bearing unit above the B -Seam and serve as downgradiant <br />monitoring wells. Based on the table accompanying the TR -103 cover letter, both sites TC -03- <br />01(B) and TC -03-02 are currently damaged and could not be rehabilitated. These two sites are <br />required to be monitored for field parameters quarterly and a full suite sample will be conducted <br />semi-annually. In order to meet the requirements of Rule 2.05.6(3) and to ensure that the <br />quality of groundwater should not be impacted, stated in the PHC section of the Bowie No. 2 <br />PAP, please provide information addressing which sites will be utilized in place of TC -03- <br />01(B) and TC -01-02 respectfully, to serve as downgradiant groundwater wells for the Upper <br />D -Seam or if BRL requests to have these wells terminated from the required monitoring plan, <br />please provide information that will serve as justification for no longer monitoring these sites <br />for field parameters and full sample suite and replacement wells will not be necessary. <br />A total of 23 monitoring sites are proposed to be temporarily suspended due to the sites not <br />being affected by mining until a date in the future. Based on the water monitoring information <br />which has been collected to date of the sites requested for temporary suspension, the Division <br />agrees to allow BRL to suspend monitoring at the listed 23 sites. However, the Division feels that <br />a commitment to re-initiate monitoring at least one year prior to a site being affected by mining <br />is required. Please provide a revision to the proposed text which includes a commitment to <br />re-initiate the monitoring of each site that is proposed to be temporarily suspended at no <br />later than one year prior to being affected by mining. <br />5. The B -Gulch up, B -Gulch low, C -Gulch up, C -Gulch low, D -Gulch up, and D -Gulch low monitoring <br />sites are requested to be permanently suspended. The B -Gulch low and C -Gulch low sites are <br />located directly above Ponds B and C respectfully. Any discharge from B -Gulch and C -Gulch will <br />be reported to Ponds B and C. The B -Gulch low and C -Gulch low sites provide data as to the <br />quality and quantity of water prior to entering the pond. This information is required prior to <br />removal of a pond or to serve as part of a justification for a pond removal demonstration. <br />Please ensure that BRL intends to permanently suspend these sites or if a temporary <br />suspension may be more appropriate <br />6. The Division agrees to permanently suspend monitoring at the following sites: <br />• Upper Hubbard Creek site based on the continued monitoring of site D34-14, up -stream from <br />the Upper Hubbard Creek site. <br />• A -Gulch low based on the absence of mine affected disturbance contributing to the potential <br />discharge of A -Gulch. <br />
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