2008-09-22_REVISION - C1996083 ‎(6)‎

• Permit No: C1996083
• IBM Index Class Name: REVISION
• Doc Date: 9/22/2008
• Doc Name: 7th Adequacy Review
• From: DRMS
• To: Bowie Resources, LLC
• Type & Sequence: PR10
• Email Name: JJD
• 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]
September 22, 2008
Mr. William A. Bear
Bowie Resources LLC
P.O. Box 483
COLORADO
D IV IS I ON OF
RECLAMATION
MINING
- rSt-
SAFETY
Bill Ritter, Jr.
Governor
Harris D. Sherman
Executive Director
Paonia, Colorado 81428 Ronald W. Cattany
Division Director
RE: Bowie No. 2 Mine, Permit No. C-1996-083, Bowie Resources LLC Natural Resource Trustee
Permit Revision No. 10, Expand B-Seam Mine Plan to the North, Seventh Adequacy Review
Dear Mr. Bear:
The Colorado Division of Reclamation, Mining and Safety (Division) has finished its review of the
HydroGeo's September 2, 2008 technical memo entitled "B-Seam and Strata Above B-Seam Water
Quality Analysis, Bowie Coal Mine." The technical memo was sent to the Division in Bowie Resources'
submittal dated September 5, 2008 as a response to item number two of the Division's adequacy review
letter dated August 1, 2008. The following are the Division's comments:
2A. The operator states that they opted to use existing groundwater baseline data rather than gather new
baseline data and that the HydroGeo report predicts down gradient water quality. The expected ranges
(Tables 3 and 4 in the Conclusions of the report) are based on previous data from existing wells.
There was no modeling performed and the predictions were based solely on ranges of known values
for pH, total dissolved solids, total Iron and total Manganese. The report further states that the "water
quality data from these wells is limited to only a few samples; therefore, any detailed statistical
analysis of the data or assessment of seasonal trends is not possible."
There is a high variability in water quality seen in the area monitoring wells which may be due to the
heterogeneous nature of the Mesa Verde Formation. The report further suggests that high pH and
TDS values may be due to poor well construction or well casing failure resulting in contamination
from cement or bentonite grout.
The Division reviewed the State Engineers Office data base for wells within the permit boundary and
adjacent down gradient areas. The Division's cursory review showed 23 well permits most of which
were for monitoring wells associated with the mining operation. There were two permits with only
very limited information, one was a domestic stock water well with no well log information and one
was for a well drilled in 1965 that was only 35 feet deep. The Division's conclusion is that there are
probably no permitted wells utilizing bedrock groundwater down gradient from the mining operation.
Although the groundwater is probably not used for domestic or agriculture uses at this time, it is still
considered potentially useable since TDS levels are less than 10,000 mg/1. For unclassified
groundwater areas, the applicable standards are the Interim Narrative Standards from Reg. 41.
The Division's position on this matter has not changed from previous adequacy review letters. The
Division does not believe that the information provided is adequate to satisfy the minimum
requirements for Ground Water Information per Rule 2.04.7 Hydrology Description. In accordance
with 2.04.7, the operator shall provide the seasonal quantity and quality of the water in each aquifer
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