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BRANNAN : <br /> yo „� <br /> To: Eric Scott, Environmental Protection Specialist RECEWFO <br /> Division of Reclamation, Mining & Safety ("Division") <br /> Room 215, c/o: Active Mines Program 20�3 <br /> 1001 E 62nd Ave. <br /> Denver, CO 80216 DIVISION OF RECLAMATION, <br /> MINING&SAFETY-MINERALS <br /> From: Steve Kelton (skelton@brannanl.com) <br /> Subject: Technical Revision 2, Nix Sand & Gravel Mine (M-2001-046), Response to Adequacy <br /> Review 2 <br /> Date: April 27, 2023 <br /> This letter is the Operator's response to an April 6, 2023 letter from the Division, styled as <br /> Adequacy Review 2 to Technical Revision 2 ("TR2"), M-2001-046 (Nix Sand and Gravel Mine). <br /> Included within are the following responsive documents, specific answers, and commitments: <br /> 1. A Sampling and Analysis Plan ("SAP") consistent with industry standards is included. The <br /> SAP includes previously submitted site characterization information (water level data, <br /> nearby active sites, well locations, groundwater contour map, etc.). The SAP also <br /> includes detailed information on water quality monitoring (see SAP Section 3). <br /> 2. The provided SAP identifies "baseline" monitoring points for the initial five quarters of <br /> baseline water quality data collection, as well as "Points of Compliance" ("POC") and <br /> background monitoring locations for follow-up annual water quality monitoring. See, for <br /> example, SAP Figure 2 and SAP Section 3.2.1. SAP Table 2 includes a brief discussion as <br /> to why the locations have been chosen. The Operator notes that it has already installed <br /> an additional water quality POC well in the northwest corner of the site and will begin <br /> sampling there this June. <br /> 3. SAP Section 4.2 includes reporting criteria and "trigger values" for potential water level <br /> deviation observed during monthly water level monitoring that may initiate additional <br /> investigation. <br /> 4. After the five quarters of baseline data are collected—the first being those samples <br /> from June, 2021—Brannan agrees to submit a Baseline Data Summary Report as a <br /> Technical Revision (see SAP Section 3.2.2.1). This Report will include all water quality <br /> and water level data collected to date, identify any exceedances in Table Value <br /> Standards, and provide a rationale for observed exceedances, if possible. <br /> The four points above further show the Operator's agreement to work with the Division to <br /> protect water quality. What it has asked for in the past, and still requests, is citation to the <br /> regulatory authority that requires such extensive, expensive, and time-consuming testing <br /> despite no evidence of Operator-caused water quality degradation. <br /> 1 <br />