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COLORADO <br />Division of Reclamation, <br />Mining and Safety <br />Department of Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Basil R. Bear <br />Bowie Resources, LLC <br />P.O. Box 483 <br />Paonia, CO 81428 <br />January 2, 2019 <br />Re: Preliminary Adequacy Concern, Bowie No. 2 Mine, Permit No. C1996083, TRI 17 <br />Dear Mr. Bear: <br />The Division has reviewed Bowie Resources, LLC application material for technical revision <br />No. 117. This revision proposes to reduce the surface water quality sampling and groundwater <br />quality sampling to once per year. The Division has identified two concerns with the submitted <br />application and requests minor modification to the application: <br />Rather than sample in "second or fourth quarter," the Division requests BRL sample in <br />second quarter, particularly for surface water. The Division believes that there will be <br />more value in collecting the water quality during higher periods of runoff when loading to <br />the river could be significant. There is the likelihood that during fourth quarter sampling <br />events there will be inadequate flow at some sampling points. The Division prefers that <br />BRL will be able to collect a sample, as opposed to a "no discharge" value. <br />2. Please revise the Hydrologic Monitoring Plan to include the commitment, "At least one <br />year before any Phase III bond release applications are submitted, BRL will resume water <br />quality full -suite sampling at least semi-annually." Resumption of more frequent sampling <br />should provide enough hydrology information for DRMS to evaluate and make findings <br />related to the bond release. <br />3. There appears to be an omission in the PAP. In the first paragraph at the top of page 2.05- <br />125, the Hubbard Creek locations are listed but not the Terror Creek locations. This is <br />confusing to the reader. Please include the Terror Creek sampling sites. <br />The proposed decision date is February 19, 2019. Response to the noted concerns in advance of <br />that date will allow the Division to review and make a decision by the regulatory timeframe. <br />Please call or e-mail me should you have any questions or require additional information. <br />1313 Sherman Street, Room 215, Denver, CO 80203 P 303.866.3567 F 303.832.8106 http://mining.state.co.us <br />John W. Hickenlooper, Governor I Robert W. Randall, Executive Director I Virginia Brannon, Director <br />