REV05840

• Permit No: C1981038
• IBM Index Class Name: Revision
• Doc Date: 7/8/2004
• Doc Name: Adequacy Review Response
• From: J.E. Stover & Associates
• To: DMG
• Type & Sequence: SO4
• Media Type: D
• Archive: No

J. J. Dudash - 2 - July 6, 2004
Rule 2.03.6
9. The Division has one comment and two additional questions:
a. As of the date of this letter, and as stated on page 15 of Section 2.03 of BRL's June 15,
2004 submittal, the transfer of the Federal coal leases has not yet been approved by the
Bureau of Land management.
b. The June 15, 2004 submitta! included a letter from the Bureau of Land Management
(BLM), dated March 5, 2004, that shows the approval of the assignment of certain Federal
rights-of-way from Bowie Resources Limited to Bowie Resources LLC. However, several
of the rights-of-way listed in this letter do not appear in the list of right-of-entry information
in Section 2.03.6 on pages 20 through 23. The right-of--way serial numbers are
COC-22266, COC-52672, COC-63617 and COC-66873. Conversely, there are several
rights-of-way listed in Section 2.03.6 that do not appear in the BLM letter dated March 5,
2004. These are numbered in Section 2.03.6 as 3, 4, 5, 6, 9, 11, 14, 21 and 22. Please
explain and revise accordingly.
BRL -Serial number COC-22266 is for the tramroad (#22). Serial
numbers COC-52672, COC-63617, and COC-66873 are applicable to the
Bowie No. 2 Mine. In Section 2.03.6, numbers 3, 4, 5, 6 and 21 are coal
leases for which assignments are pending. Numbers 9 and 11 are no
longer required because the facilities have been removed. Appropriate
explanations were added to pages 21 and 23. 1 sent an a-mail to the BLM
which inquires about the status of number 14, C-44583.
c. As required in Rule 2.03.6(1), please add a statement in Section 2.03.6 as to
whether any of the listed right-of-entries are the subject of pending litigation.
BRL -The required statement is presented in the third paragraph on page
15, revision date 6/04.
Rule 2.03.9
11. This issue has not been resolved yet. BRL submitted a revised insurance certificate but
both the Sowie No. 1 Mine and the Bowie No. 2 Mine were listed on the certificate. Each
mine has to have its own insurance certificate.
BRL - No response at this time.
Rule 2.03.10
12. The Division has two additional questions:
a. On revised page 33 of Section 2.03.10 of the June 15, 2004 submittal, the NPDES permit
and the Stormwater permit are listed as being expired. Please update this information to
show if new permits were applied for or already approved.
BRL -BRL has been issued a new discharge permit. The Stormwater
permit is now a general permit which has the same number and expiration
date as the CDPS general permit. The appropriate information was