2010-12-22_REVISION - C1996083

• Permit No: C1996083
• IBM Index Class Name: REVISION
• Doc Date: 12/22/2010
• Doc Name: Adequacy Review
• From: DRMS
• To: Bowie Resources, LLC
• Type & Sequence: TR69
• Email Name: JJD
• Email Name: SB1
• 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
Phone: [phone]
FAX: [phone]
December 22, 2010
Mr. William A. Bear
Bowie Resources LLC
P.O. Box 483
Paonia, Colorado 81428
RE: Bowie No. 2 Mine, Permit No. C-1996-083, Bowie Resources LLC
Technical Revision No. 69, Ownership Change, AVS Issue
Dear Mr. Bear:
COLORADO
D I V I S ION OF
RECLAMATION
MINING
SAFETY
Bill Ritter, Jr.
Governor
Mike King
Executive Director
Loretta E. Pineda
Director
The Colorado Division of Reclamation, Mining and Safety (Division) has finished its adequacy review
of Technical Revision No. 69 (TR-69), submitted by Bowie Resources LLC (BRL) for the Bowie No.
2 Mine. The Division has no specific adequacy review questions concerning TR-69. However, as part
of the TR-69 adequacy review, the Division did a check of the Applicant Violator System (AVS) and
found an issue that needs to be resolved.
As shown on proposed revised page 2.03-32 of TR-69, Jeffrey W. Krol owns 50% of C&K Bowie,
LLC. C&K Bowie, LLC, in turn, owns 10% of Cedars Energy, LLC. Cedars Energy, LLC owns 45%
of Bowie Resources, LLC. Jeffrey W. Krol is linked in AVS with one AML violation and two state
cessation orders. Please refer to the attached AVS printouts for the specific details of the violations.
The proposed decision for TR-69 depends on the successful resolution of this issue. In addition, the
proposed decisions for Minor Revision No. 122 for the Bowie No. 2 Mine and Permit Revision No. 4
for the Bowie No. 1 Mine also depend on the successful resolution of this issue.
There are three possible avenues of approach that BRL can take to resolve this issue. First, the one
AML violation and the two state cessation orders can be resolved and the AVS updated so that the
violations would no longer be linked to Jeffrey W. Krol.
Second, the link between Jeffrey W. Krol and the violations could be severed in AVS through an
appropriate reduction in ownership in C&K Bowie LLC or through a demonstration that Jeffrey W.
Krol can be excluded from the violations.
Third, referring to Rule 1.04(83a)(b), BRL can provide documentation to the Division which
demonstrates that Jeffrey W. Krol does not have direct or indirect authority over any of the Bowie
Resources LLC operations, including the Bowie No. 1 Mine and the Bowie No. 2 Mine.
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