2010-05-14_REVISION - C1996083

• Permit No: C1996083
• IBM Index Class Name: Revision
• Doc Date: 5/14/2010
• Doc Name: Adequacy Memo
• From: Mike Boulay
• To: Joe Dudash
• Type & Sequence: PR12
• Email Name: JJD
• Email Name: MPB
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
COLORADO
D I V I S I ON OF
RECLAMATION
MINING
SAFETY
Bilf Ritter, Jr.
INTEROFFICE MEMORANDUM Govemor
James B. Martin
Executive Director
TO: Joe Dudash
FROM: Mike Boulay MB
DATE: May 14, 2010
SUBJECT: Bowie No. 2 Mine, Permit No. C -96 -083, Permit Revision No. 12 (PR -12)
As requested, I have reviewed Bowie Resources, LLC (BRL's) PR -12 application with regard to
groundwater related issues. In our recent reviews of PR -09, PR -10, and PR -11 we have extensively
reviewed and commented on the adequacy of the Bowie No. 2 Mine's groundwater monitoring
program. We have made substantial progress with the most noteworthy being BRLs successful
demonstration that the Rollins Sandstone should not be impacted by the current mining operation.
This relieved BRL from installing very deep down gradient wells in areas of difficult terrain and
limited road access. Also noteworthy, were the approval of PR -10 and the acceptance of the
HydroGeo, Inc. report prepared in September 2008 for the Bowie No.2 Mine. This document was
incorporated into the permit application package (PAP) in Volume III, Exhibit 3 and demonstrated
that the existing baseline and operational groundwater quality data for the B -Seam and strata above
the B -Sea1n does not vary much from south to north within the current permit area and there is no
reason to expect the water quality to change further to the north beyond the current pen-nit
boundary. The Division accepted this B -Seam and Strata above the B -Seam Water Quality
Analysis and granted relieve to BRL from the need to drill additional down gradient monitoring
wells again in difficult, steep terrain with very limited road access. Hence, as it exists today, the
Division has deemed BRL's existing groundwater monitoring program adequate and appropriate
for the current pen area of the Bowie No. 2 Mine.
With PR -12, BRL presents a new western mine plan whereby they propose to develop access to the
west under Terror Creek to mine the coal in Bowie No. 1 Mine east pod. Coal would be mined
from leases that were originally part of Bowie No. 1 permit but by this revision appropriate portions
of the leases would be incorporated into the Bowie No. 2 permit. Essentially, the majority of the
former Bowie No. 1 permit area would be incorporated into the Bowie No. 2 permit. I have the
following adequacy review comments regarding PR -12.
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines