2008-02-15_REVISION - C1996083 (3)

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STATE OF COLORADO DIVISION OF RECLAMATION', MINING AND SAFETY Department of Natural Resources 1313 Sherman St., Room 215 Denver, Colorado 80203 Phone: (303) 866-3567 FAX: (303) 832-8106 February 15, 2008 COLORADO DIVISION O F RECLAMATION MINING - &- SAFETY Bill Ritter,lr. Governor Mr. William A. Be~ir Harris D. Sherman Bowie Resources LLC Executive Director P.O. Box 483 Ronald W. Cattany Paonia, Colorado 81428 Division Director Natural Resource Trustee RE: Bowie No. 2 Mine, Permit No. C-96-083, Bowie Resources LLC Technical Revision No. 51, Keep Excess Rock at Paonia Sewage Lagoons, Second Adequacy Review Dear Mr. Bear: The Colorado Divi~lion of Reclamation, Mining and Safety (Division) has finished its adequacy review of Bowie Resources LLC's (BRL) February 4, 2008 responses to the Division's January 11, 2008 adequacy review letter for Technical Revision No. 51 (TR-51) for the Bowie No. 2 Mine. The following is the status of the Division's concerns. 1. Please proi~ide a geochemical analysis of the excess rock currently at the Paonia sewage lagoons that shows that the material is non-toxic and non-acid forming. Based on tl-e single analysis report submitted, it appears as though the rock is, in fact, inert, and meets established guidelines for nontoxic, non-acid forming materials. The Division does have several basic questions pertaining to the lab results as a whole. A. BRL states that the sample that was analyzed is a "representative sample". Given that 1,700 tons of rock were hauled to the Paonia sewage lagoons, the Division would like to know how'the sample was taken and why it is believed that a single sample is a representative sample. B. Assuming that the sample was taken correctly, as asked in question 1 above, the next quc;stion is how was the sample prepared. Either a written description of the sample preparation procedure (from the laboratory) or a reference to a standard method or procedure for sample preparation would be acceptable. C. Although the analysis results show a basic methodology used in analyzing the sample (saturated paste extraction, hot water extraction, etc.), the Division would like a more specific method for each parameter listed (for example, USDA method x, USEPA method Y, etc.). D. There are several constituents that were analyzed that were given a "U" value, which indicates that the value for that constituent was less than the method detection limit (MDL). Although this is standard practice, the Division would like to know what these ML)L's are in order to verify that the MDL is low enough to be below the suitability level for each constituent. Office of Office of Mined Land Reclamation Denver Grand Junction Durango Active and Inactive Mines