2008-07-28_REVISION - C1996083 ‎(2)‎

• Permit No: C1996083
• IBM Index Class Name: REVISION
• Doc Date: 7/28/2008
• Doc Name: Review/Response Memo
• From: Mike Boulay
• To: Joe Dudash
• Type & Sequence: PR10
• 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 INTEROFFICE MEMORANDUM
Phone: [phone]
FAX: [phone]
TO: Joe Dudash
FROM: Mike Boulay Mt&
DATE: July 28, 2008
SUBJECT: Bowie No. 2 Mine, Permit No. C-1996-083
Permit Revision No. 10
S?p??•tc0
COLORADO
D I V I S I ON OF
RECLAMATION
MINING
- St:-
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. I also met with
Collin Stewart of BRL and their consultants Jim Stover and George Robinson on July 10, 2008 to
discuss groundwater monitoring with respect to PR-10 and PR-11, and the possibility of BRL
appearing before WQCC to have the perched and coal aquifers classified as "Limited Use and
Quality". One action item to come out of the meeting for DRMS was to discuss amongst ourselves
whether or not additional baseline data would be needed for the perched water zones and coal aquifers
as they expand into a new area to the north or would the existing well data already obtained be
sufficient. Collin Stewart and George Robinson stated that alternatively they could possibly obtain
baseline information in other ways such as collecting water quality samples during development
mining. Clearly additional down gradient monitoring wells will be required for the perched water
zones and coal aquifers unless they are successful at obtaining a groundwater classification of "Limited
Use and Quality" through the WQCC hearing process.
Based on our discussions in the July 10 meeting and my review of BRL's May 12, 2008 adequacy
response to Item 2, I have the following comments which hopefully will help to resolve the remaining
groundwater issues.
An important point the Division wants to get across, is that if BRL wants to use existing
baseline data rather than gather new baseline data, they have to demonstrate with the existing
data that the baseline water quality hasn't changed much as you go from south to north within
the current permit area, and, then, demonstrate that there is no reason to expect that situation to
change as you go even further to the north beyond the current permit boundary (for the mine
plans in PR-10 and PR-11). BRL should demonstrate to the Division that the existing wells
will satisfy baseline data collection requirements Rules 2.04.7(1) and 2.04.7(4) (c). BRL has
indicated the possibility of obtaining baseline information through alternative means such as
sampling during development mining. The alternative means for acquiring baseline data is
suggested by BRL due to several circumstances including difficult terrain, technical difficulty
in drilling extremely deep wells and USFS issues regarding limited access to drill locations.
This alternative demonstration if acceptable to the Division should be implemented prior to
disturbing beyond the approved disturbance boundary to the north. If BRL cannot demonstrate
that the existing well data is adequate for the entire new permit area proposed with PR-10 and
PR-11 or cannot provide a suitable alternative means for data collection, then the Division
would require additional baseline monitoring wells.
Office of
Mined Land Reclamation
Denver - Grand )unction - Durango
Office of
Active and Inactive Mines