2008-09-22_REVISION - C1996083 ‎(7)‎

• Permit No: C1996083
• IBM Index Class Name: REVISION
• Doc Date: 9/22/2008
• Doc Name: Review Memo
• From: Mike Boulay
• To: Joe Dudash
• Type & Sequence: PR10
• Email Name: MPB
• 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 Boulay MF
DATE: September 22, 2008
SUBJECT: Bowie No. 2 Mine Permit No. C-1996-083
Permit Revision No. 10
COLORADO
DIVISION OF
RECLAMATION
MINING
SAFETY
Bill Ritter, Jr.
Governor
Harris D. Sherman
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
As requested, I have reviewed Bowie Resources, LLC's (BRL's) response to Item 2 of our adequacy
review for PR-10 regarding groundwater monitoring including points of compliance. Specifically I
have reviewed the recent responses submitted by J.E. Stover & Associates, Inc. dated September 5,
2008 and the report prepared by HydroGeo, Inc. for the B-Seam and strata above B-Seam water
quality analysis. I have the following 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.
I reviewed the State Engineers Office data base for wells within the permit boundary and
adjacent down gradient areas. My 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. My
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