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2023-04-07_REVISION - M2001046
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2023-04-07_REVISION - M2001046
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Last modified
4/10/2023 8:55:31 PM
Creation date
4/10/2023 8:04:51 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2001046
IBM Index Class Name
Revision
Doc Date
4/7/2023
Doc Name
Adequacy Review Response
From
Brannon Sand & Gravel
To
DRMS
Type & Sequence
TR2
Email Name
ECS
MAC
Media Type
D
Archive
No
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The only remaining loose end, as we see it, was to submit a TR as required by the final Exhibit G: <br /> R EXHIBIT G-11 ater Information(Rule 6.4.7): <br /> The following information is still required for Exhibit G_ <br /> • As discussed during June 22 phone call,The operator will commit to submitting a technical rexnsion <br /> containing the baseline analytical results compared to standards of Tables 1-4 of the Interim Narrative <br /> Standard prior to mining. The re nsion will also contain a detailed Sampling and Analysis plan describing <br /> how the operator will monitor groundwater conditions,as well as insure/document that the water quality <br /> will meet the Interim Narrative Standards during operation and prior to release-please acknowledge. <br /> Our recently submitted TR provided exactly what was requested: the baseline analytical results compared to standards, and a detailed Sampling and Analysis plan. <br /> Brannan has relied upon these communications and has complied with the letter and spirit of the requirements. Because of our good faith efforts and the lack of any evidence pointing to water quality <br /> degradation as a result of our operations—which haven't even started yet—we're asking you to accept the already agreed-upon annual monitoring plan that will commence along with our mine opening, the <br /> results of which will be included in our annual report. <br /> Thank you for your consideration, <br /> Steve <br /> From:Scott- DNR, Eric<eric.scott@state.co.us> <br /> Sent:Thursday, March 2, 2023 9:31 AM <br /> To: Steve Kelton <skelton@ bran nanl.com> <br /> Subject: [EXTERNAL] Re:TR for M-2001046 <br /> I just took a brief look at the data you submitted for Nix.. Generally we try to get 5 quarters of background/baseline data (to account for seasonal variation, etc.)to compare to INS table values prior to adopting <br /> standards in excess of Table Value Standards.. Please continue to collect additional baseline data and call if you have any questions. I will review further when the fee arrives and the revision is officially"filed" <br /> but I wanted to give you a heads up that additional sampling would be required.. <br /> Eric Scott <br /> Environmental Protection Sp ecialist, P.G., R.G. <br /> X <br /> P 303.866.3567 x 8140 1 F 303.832.8106 <br /> 2 <br />
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