2007-08-13_HYDROLOGY - C1996083

• Permit No: C1996083
• IBM Index Class Name: HYDROLOGY
• Doc Date: 8/13/2007
• Doc Name: Adequacy Review of Groundwater Points of Compliance Techincal Report
• From: Mike Boulay
• To: Joe Dudash
• Permit Index Doc Type: Correspondence
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING ANp 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
DATE: August 13, 2007
SUBJECT: Bowie No. 2 Mine, Permit No. C-1996-083
Adequacy Review of
Groundwater Points of Compliance Technical Report
COLORADO
DIVISION O F
RECLAMATION
MINING
- &-
SAFETY
Bill Ritter, Jr.
Governor
Harris D. Sherman
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
As requested, I reviewed the R Squared Incorporated Technical Report requesting a
variance from establishing groundwater compliance points for the Bowie No. 2 Mine
where the depth to groundwater is greater than 300 feet. I also reviewed the latest
Findings, AHR Reports, previous review memos, and permit application package (PAP)
Sections 2.04.5, 2.04.7 and 2.05.6.
A lot of the information presented in the report could be used to substantiate a
determination of no signif cant impact to bedrock ground water, or possibly to establish a
site-specific classification of "Limited Use and Quality" for bedrock ground water at the
mine and adjacent areas. However, as presented in the report, the approach to exempting
groundwater monitoring or establishing alternative points of compliance is not an
allowable application of the ground water regulations. I have the following comments
regarding the overall approach to the variance request and the validity of such request.
1. The Division of Reclamation, Mining and Safety (Division) as an implementing
agency does not have the authority or provisions in our regulations to grant a variance
from establishing groundwater points of compliance. Further, groundwater monitoring
would not be exempted as indicated in the report due to its non-tributary nature or limited
existence. This would be an inappropriate application of groundwater quality
regulations. Under the Colorado Water Quality Control Act (CWQCA) State Waters
include all groundwater regardless of yield. For unclassified groundwater areas (as is the
case for Bowie No. 2 Mine), the applicable and relevant standards are the Interim
Narrative Standards (41.5(C)(6)) from Regulation 41, The Basic Standards for Ground
Water.
2. The "alternative compliance point" described in section 3 of the report is not
defined by regulation. The Water Quality Control Commission (WQCC) may grant
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