PERMFILE45069 - Laserfiche WebLink

Home Browse Search

.. ~ iii iiiiiiiiiiiii iii -. • Michael B. Long ~Y / Division of Minerals and Geology ~ `~1~~~~ ~ ~~CEIVEC Department of Natural Resources' 1~ 1313 Sherman, Room 215 ~~ G ~ ~_ J,, Q~' Q ] 1997 Denver, Co 80203 ~G„ k /~/ October 2, 1997 ~~° 7 v '~ ~ ,~wisien of rvwieiais ~ c:eciery - J~ Dear Mike, r, ~ jGZwpn.~ ~ Thank you for taking the time to discuss some of the environmental concerns with the proposed Agile Stone System Parkdale Project (112 Permit a plication, M-97-054) As we indicated, Clean Water Action, Audubon, and Colorado Trout Unlimited remain concerned over the projects potential impacts on both water quality and water quantity. It is our understanding that there may be a substantial amount of pyrite in the area. If it is true that metallic sulfides are present in the rock and soil, then the potential for acid generation from these materials would require considerable pre-project analysis of baseline conditions, detailed assurances that acid generation would not result in any adverse impacts to local surface and ground waters, and reclamation bonding requirements to cover any mitigation and/or control structures required to meet state and federal water quality requirements. Although under the Construction Materials Rules such an operation would not be specifically classified as a Designated Mining Operation as under the Minerals Rules, the Division is still obligated to prevent acid mine drainage and protect water quality from construction material mines in a similar fashion. Under Construction Rules 3 and 6, the applicant cannot receive a permit until it assures the Division/Board that "all refuse and acid-forming or toxic producing materials... shall be handled and disposed of in a manner that will... protect the drainage system from pollution." 3.1.5, see also 34-32.5-116(4); Rule 6.3.3. Without an analysis of the potential for such materials to create such conditions, an applicant cannot meet these requirements. Due to the likelihood that drainage from the project area will reach both surface and ground waters, detailed water quality protection plans for these resources must be forthcoming from the applicant prior to permitting. It should be noted that these requirements are mandatory if there is a potential for any acid or toxic-forming materials to occur on site -they do not become mandatory only if such formation is likely. It does not appear at the present time that the applicant has provided the required baseline studies of surface and ground waters, acid mine production analysis (if pyrite is present), and operational and reclamation features that will protect surface and ground waters from pollution. A complete review of the sources and pathways for any contaminants to reach surface and/or ground waters must be conducted. Until all of this information is forthcoming, the application is incomplete and cannot be approved. We suggest that if field analysis determines that acid preduction is possible, then additional static and dynamic tests should be conducted to more fully ascertain the potential for acid production. Proper attention should be made to ensure that testing is done under conditions which include the presence of thiobacillus ferroxidans and that short-term neutralization reactions in the sample do not skew the results towards an overly optimistic acid neutralization/production ratio. In any event, the Division should not complete its review of the application until all long-term kinetic and batch tests have been completed (i.e., at least 20 weeks). Another important concern regards the potential for the local clay to release Phos horns (primarily via sediments) to the Arkansas River system. Much of the clay in Colorado does contain phosphorous. Eutrophication of reservoirs and lakes in the system is a serious