2012-11-20_REVISION - C1996083 (4)

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John W. Hickenlooper Governor INTEROFFICE MEMORANDUM Mike King Executive Director Loretta E. Pineda Director TO: Susan Burgmaier FROM: Mike Boulay DATE: November 20, 2012 SUBJECT: Bowie No. 2 Mine, Permit No. C -96 -083, Permit Revision No. 13 (PR -13) As requested, I have reviewed Bowie Resources, LLC (BRL's) PR -13 application with regard to groundwater related issues. In our past reviews of PR -09 through PR -12 we have studied 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 (below the lowest coal seam to be mined) should not be impacted by the current mining operation including the west expansion area which applies to PR -12 and PR -13. This relieves 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 -Seam does not vary much from south to north within the permit area and there is no reason to expect the water quality to change further to the north beyond the current permit 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 located to the north of the original Bowie No 2 Mine east of Terror Creek. With PR -12, BRL presented a new western mine plan whereby they were approved to develop access to the west under Terror Creek to mine the coal in Bowie No. 1 Mine east pod area. As part of the PR -12 approval BRL was required to update the monitoring program to incorporate both up gradient and down gradient groundwater monitoring wells for the proposed western mine plan. Two existing wells from the Bowie No. 1 Mine were included as up gradient monitoring wells. BRL identified a location with good access for two additional down gradient wells and these were installed in 2011. The location for the newer down gradient wells is identified on Map 09 as 2010 -1; one is completed and screened in the Upper B Seam Coal and one in the B Sandstone above the coal. Both of these wells exceed 1200 feet in depth.