2008-04-09_REVISION - C1996083 ‎(2)‎

• Permit No: C1996083
• IBM Index Class Name: REVISION
• Doc Date: 4/9/2008
• Doc Name: Review Letter Memo
• From: Mike Boulay
• To: Joe Dudash
• Type & Sequence: PR11
• Email Name: SB1
• 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]
INTEROFFICE MEMORANDUM
TO: Joe Dudash
FROM: Mike Boutay /~~
DATE: A.pri109, 2008
SUBJECT: Bowie No. 2 Mine, Permit No. C-96-083, Permit Revision No. 11
COLORADO
D I V I S I O N O F
RECLAMATION
MINING
~. &___..
SAFETY
Bill Ritter, Jr.
Governor
Harris D. Sherman
Executive Director
Ronald W. Cottony
Division Director
Natural Resource Trustee
As requested, I have reviewed Bowie Resources, LLC (BRL) PR-11 application. In our previous
reviews of PR-OSI and PR-10, we indicated that the proposed extension of the B-Seam Mine Plan to
the north would result in a lack of goundwater monitoring wells down gradient of the mining
disturbance. Do~am-gadient monitoring of groundwater is critical in determining potential impacts
to groundwater and the hydrologic balance, as required by our rules. Likewise PR-11 proposes no
new monitoring wells down gradient of the proposed mine disturbance. It is unclear how the
requirements of 4.05 will be adhered to without down gradient monitoring of groundwater. Rule
4.05.13(3) (b) requires that monitoring of groundwater continues until after cessation of use of
underground mine workings and until it is demonstrated that the operation has minimized
disturbance to the hydrologic balance in the permit and adjacent areas. Ground water monitoring
will be required throughout the bond liability period.
BRL has submitted a draft Groundwater Points of Compliance Technical Report and a second draft
Groundwater Classification and Compliance Report. The DRMS has provided BRL with a
preliminary review of each of these reports in our letters dated August 13, 2007 and March 20,
2008, respectively. BRL has presented information in these draft reports that may assist the DRMS
in making a judgment regazding the potential for the operation to negatively impact groundwater.
This is important with regard to the need for groundwater points of compliance [Rule 4.05.13(1)
(b)]. There is already discussion in the Probable Hydrologic Consequences (PHC) regarding the
fact that confining shale layers and piezometric head should prevent any integration of water
from either the I)-Seam or B-Seam into the underlying Rollins sandstone. The DRMS generally
concurs with this and recommends that the information presented in the report(s) be incorporated
into the PAP through a revision application to expand upon previous Findings regarding the
potential impacts to the Rollins sandstone. If the case for the Rollins sandstone is adequately
presented through a technical revision and approved by the DRMS, we would not require a point
of compliance well in the Rollins sandstone. As stated in our recent correspondence and
discussions with BRL, the potential impacts to the Upper and Lower Perched Water Zones are
not as clearly defined.
Office of Office of
Mined Land Reclamation Denver Grand Junction Durango Alive and Inactive Mines