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r <br /> Greg LeNvicki And Associates, PLLC <br /> 3375 NN. PoNNers Circle Phuue: (7211) 842-5321 Lai (303)346 6934 <br /> Littleton,( 0 811123 L-mail: info a leNNicld.hii <br /> January 8, 2020 RECEIVED <br /> Delivered Via Email and Hard Copy JAN 13 ZOZQ <br /> Dustin Czapla OMSION OF RECLAMATION <br /> Colorado Division of Reclamation, Mining and Safety MINING&SAFETY <br /> 1313 Sherman Street, Room 215 <br /> Denver, CO 80203 <br /> dustin.czaplagstate.co.us <br /> RE: The Pride of America Mine, Permit#M-1999-058, October 2019 Diesel Spill <br /> Report, Clarification Issues - Colorado Stone Quarries' (CSQ) Response <br /> Mr. Czapla: <br /> I am responding to your December 27, 2019 letter to me concerning the October I1 th, 2019 <br /> Diesel Spill Report, dated November 27, 2019, which was prepared by Greg Lewicki and <br /> Associates, PLLC (GLA) (the "Spill Report"). Specifically, the Division requested additional <br /> discussion or clarification regarding two identified issues. Those issues are presented below <br /> along with our responses. <br /> DRMS Comment: The report concludes that no diesel appears to have left the site and no <br /> discharge of contaminated water occurred at any time during the initial spill or mitigation. <br /> This conclusion is not accurate based on the fact that detectable amounts of BTEX were <br /> found in the DG3 sample following the flushing efforts. Except for Xylenes detected in the <br /> DG4 sample post-flushing, the DG4 and DG5 sample points did not show detectable <br /> amounts of contaminants related to the spill,which could be explained through dilution by <br /> Yule Creek. However, it is clear that at least some contaminates entered Yule Creek <br /> following the spill. Please correct or clarify the conclusion that no detectable amount of <br /> contaminated water reached Yule Creek. <br /> Response: The focus of our discussion in the Spill Report regarding the results of water quality <br /> sampling conducted in response to the October spill was intended to be on gasoline range <br /> organics (GRO) and diesel range organics (DRO). As discussed in the Spill Report and shown in <br /> its Appendix G,the only samples that contained DRO or GRO concentrations above detection <br /> limits were collected from the sump. No diesel fuel (i.e., free phase product) appears to have <br /> migrated off the site and into Yule Creek, but rather was contained within the sump area above <br /> the creek. The statement that no detectable amount of contaminated water reached Yule Creek <br /> as a result of the spill, however, was imprecise. As noted in your comment and as shown in <br /> Appendix G, trace amounts of certain BTEX components (i.e., toluene, ethylbenzene and <br /> 1 <br />