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Sandy Brown <br />July 25, 2008 Page 2 <br />considering going to the Commission, I suggested that Bowie first obtain a very clear picture of the <br />data they have by preparing cross-sections for each aquifer/specified area and determining whether or <br />not they would meet groundwater standards at select points of compliance. If they can meet <br />groundwater standards at selected points of compliance than that may be a better option than going <br />before the Commission. <br />George Robinson indicated that they would be going forward with meeting with the Water Quality <br />Control Division first, and then would prepare for a hearing before the Water Quality Control <br />Commission to obtain a site-specific classification of "Limited Use and Quality" for the Bowie No. 2 <br />Mine for the upper and lower perched aquifers. The hearing would likely not occur until November <br />2008 at the earliest. George also indicated that he has been talking with members of the Colorado <br />Mining Association and some consideration has been given to a joint effort between the coal <br />operators to obtain certain variances through the WQCC. He mentioned revisiting the draft point of <br />compliance paper that our Division prepared back in August 2002 as a good starting position. He <br />clearly indicated that the support of our Division would be necessary for any success at obtaining <br />site-specific classifications and/or variances through the WQCC hearing process. <br />Permit Revision No.'s 10 and 11 were discussed with regard to expanding the permit boundary to the <br />north beyond the current limit of groundwater monitoring. During the meeting, we talked about <br />Bowie needing PR-10 and PR-11 approved by September. So the WQCC hearing process in <br />November as described above would be too late. They are proposing to move northwards by more <br />than a mile. The discussion focused on whether the existing well DH-65 and DH-67 cluster of wells <br />would satisfy the requirements for baseline monitoring as they move into a new area and whether or <br />not additional monitoring would be required. The confining shale layers below the lowest coal seam <br />and the piezometric head differences between the Rollins Sandstone and the overburden should <br />prevent integration of water into the Rollins. This will need to be documented in the PAP and <br />updated in our Findings. My recommendation is to approve the no impact argument for the Rollins <br />and therefore we need only focus on the perched water zones as the permit boundary is expanded to <br />the north. <br />The only immediate action item to come out of the meeting for DRMS was to discuss amongst <br />ourselves whether or not additional baseline data would be needed for the perched water zones or <br />would the existing data already obtained be sufficient as they expand into a new area to the north. <br />Collin Stewart and George Robinson stated that they could possibly show other ways of obtaining <br />baseline information such as collecting water quality samples during development mining. <br />Clearly additional down gradient monitoring wells will be required for the perched water zones <br />unless they are successful at obtaining a groundwater classification of "Limited Use and Quality" <br />through the WQCC hearing process. Bowie has agreed to install additional monitoring wells in their <br />May 12, 2008 Item 2 response to PR-10. <br />c: Joe Dudash and Denver File