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Cresson Project – AM-11 Adequacy Review No. 2 <br />Page 3 <br />October 19, 2016 <br /> <br />Weak Acid Dissociable Cyanide) for each of the drainages where compliance monitoring <br />is required (Arequa Gulch, Grassy Valley, Vindicator Valley, Wilson Creek). However, <br />the Operator did not provide NPLs for the groundwater compliance monitoring wells <br />located in Squaw Gulch or Poverty Gulch (shown on revised Figure 2-1). Please propose <br />NPLs for all groundwater compliance monitoring wells. <br /> <br />The revised Table 2-1 does not include NPLs for surface water compliance monitoring <br />sites as requested. Please propose NPLs for all surface water compliance monitoring <br />sites. <br /> <br />The Division requires the Operator to propose NPLs for all compliance monitoring wells <br />and surface water monitoring sites. Please be advised the Division’s approval of AM-11 <br />would not constitute a permanent approval of the NPLs presented in AM-11. Pursuant to <br />Rules 6.4.21(9)(c) and 6.4.21(11)(c), the analytical detection limits and water quality <br />parameters must be acceptable to the Division. The Division reserves the right to review <br />and modify NPLs for any compliance water monitoring locations subsequent to the <br />approval of AM-11. <br /> <br />(Volume I of IV) <br /> <br />Exhibit G – Water Information - Project Description <br /> <br />4.6.3 Summary <br /> <br />73) The Operator’s response did not satisfy the requirements of Rules 6.4.7(2)(c), 6.4.21(12), <br />3.1.5(10), and 3.1.6(1), because it did not adequately describe how the operation would <br />differentiate impact to surface water quality from historic mine features versus impact <br />from mining activities occurring under this permit. Please provide additional information <br />that demonstrates how the operation would identify potential impact to surface water <br />from current mining activities. <br /> <br />If you have any questions, please contact me by telephone at (303) 866-3567, ext. 8129, or by <br />email at amy.eschberger@state.co.us. <br /> <br />Sincerely, <br /> <br /> <br />Amy Eschberger <br />Environmental Protection Specialist <br /> <br />Cc: Wally Erickson, DRMS