2008-03-20_HYDROLOGY - C1996083

• Permit No: C1996083
• IBM Index Class Name: HYDROLOGY
• Doc Date: 3/20/2008
• Doc Name: Groundwater Classification and Groundwater Compliance Report
• From: DRMS
• To: Mr George Robinson
• Permit Index Doc Type: Correspondence
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
COLORADO
DIVISION O F
RECLAMA'T'ION
MINING
- &-
SAF ETY
March 20, 2008 Bill Ritter, )r.
Governor
Mr. George Robinson Harris D. Sherman
R2 Incorporated

9034 E. Easter Pl., Suite 201
Centennial, CO 801 12 Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
RE: Groundwater Classification and Groundwater Compliance Report
Bowie No. 2 Mine, Permit No. C-1996-083
Dear Mr. Robinson:
You asked that we take a look at your report regarding points of compliance and ground
water classification for the Bowie No. 2 Mine. Please be advised we did not complete a
full technical review of the report. It will be necessary for Bowie Resources LLC to
submit a technical revision to their permit addressing the point of compliance issue. At
that time we will complete a full review. I did ask Mike Boulay to look at this report
however and we offer the following comments.
This report was a big improvement over the last submittal. In the cover letter it is
indicated that one goal is to exclude monitoring ground waters within the permit area.
We cannot give an exclusion for groundwater monitoring. Groundwater monitoring is
required throughout the liability period. We will continue to require monitoring of
existing wells (we do have the option of relaxing the sampling schedule until a later date
such as bond release time). If mining advances into a new area where baseline data is not
established we may require additional monitoring wells.
What we can do is make a judgement based on sound information that the operation has
no potential to negatively impact groundwater and therefore not require a point of
compliance well. A good case could be made for the Rollins Sandstone in this regard.
However, all groundwater has to be addressed including the perched water zones and
alluvial groundwater. It is unclear if the perched zones are specifically addressed by this
report. Mike found no mention of alluvial groundwater.
Further you are requesting that we waive the requirement for establishing groundwater
compliance monitoring wells for the Bowie Mine. The only way to do this would be
through a determination of no impact and therefore not require points of compliance.
Again this would have to address all groundwater including the bedrock groundwater in
the Rollins, the perched zones described in the permit, and alluvial groundwater. The
Office of Office of
Mined Land Reclamation Denver Grand Junction Durango Active and Inactive Mines