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Sandy Brown <br />March 27, 2009 Page 2 <br />I don't think it is appropriate to assume that the geologic and hydrologic conditions (in particular the <br />presence or absence of perched aquifers) above the coal seam are the same for the proposed <br />expansion area as was previously encountered at Bowie No. l and 2. Bowie has already drilled two <br />exploration holes in the area that have been plugged and abandoned. Since they will be drilling <br />several more they will at least make an attempt to install two baseline data collection wells as <br />described above. Other requirements of Rules 2.04.6 and 2.04.7 would be satisfied by updating <br />appropriate maps and cross-sections with the information obtained by the exploration drilling. <br />We do need to consider the very difficult conditions for installing and sampling monitoring wells at <br />these depths (1600 to 2000 feet below ground surface). Mud-rotary would be required which <br />makes it difficult to identify saturated conditions during drilling and difficult to properly develop a <br />constructed well. Purging and sampling wells at these depths is also problematic. We discussed the <br />use of geophysical logs to possibly identify saturated zones if they are unsuccessful in doing so <br />during drilling. We also discussed the use of dedicated sampling pumps or the use of compressed air <br />to purge and sample wells one they are installed. <br />The monitoring program and points of compliance as required by 4.05.13 will be evaluated based on <br />success of the drilling and exploration. No additional monitoring or paint(s) of compliance will be <br />necessary for the Rollins Sandstone. <br />Finally we discussed points of compliance for the Bowie No. 2 Mine. Bowie has not established <br />points of compliance for Bowie No. 2. We discussed some ideas for establishing points of <br />compliance for the perched bedrock aquifers/saturated zones and alluvial groundwater present <br />between the disturbed areas and the North Fork of the Gunnison River. Bowie may be able to make <br />the case that it is unlikely that their mining operation would impact bedrock groundwater off-site and <br />therefore point(s) of compliance are not warranted in the perched aquifers down-dip of the mine <br />workings. This would have to be very well documented. Some of the issues we discussed were the <br />very limited extent of the perched aquifers, lack of groundwater use in the area, and technical <br />feasibility of domestic or agricultural use due to low permeability and depth to groundwater. We <br />briefly reviewed the location of existing alluvial wells and identified AW-14 as a good candidate for <br />an alluvial point of compliance well. <br />Please let me know if you have any questions regarding the groundwater issues we discussed in our <br />meeting at J.E. Stover & Associates office yesterday. <br />c: Joe Dudash <br />Denver File