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PERMFILE45069
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PERMFILE45069
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Entry Properties
Last modified
8/24/2016 10:47:29 PM
Creation date
11/20/2007 12:11:01 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1997054
IBM Index Class Name
Permit File
Doc Date
10/7/1997
To
DMG
Media Type
D
Archive
No
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.. ~ iii iiiiiiiiiiiii iii <br />-. • Michael B. Long ~Y / <br />Division of Minerals and Geology ~ `~1~~~~ ~ ~~CEIVEC <br />Department of Natural Resources' 1~ <br />1313 Sherman, Room 215 ~~ G ~ ~_ J,, Q~' Q ] 1997 <br />Denver, Co 80203 ~G„ k /~/ <br />October 2, 1997 ~~° 7 v '~ ~ ,~wisien of rvwieiais ~ c:eciery <br />- J~ <br />Dear Mike, <br />r, ~ <br />jGZwpn.~ ~ <br />Thank you for taking the time to discuss some of the environmental concerns with the <br />proposed Agile Stone System Parkdale Project (112 Permit a plication, M-97-054) As we <br />indicated, Clean Water Action, Audubon, and Colorado Trout Unlimited remain <br />concerned over the projects potential impacts on both water quality and water quantity. <br />It is our understanding that there may be a substantial amount of pyrite in the area. If it is <br />true that metallic sulfides are present in the rock and soil, then the potential for acid <br />generation from these materials would require considerable pre-project analysis of <br />baseline conditions, detailed assurances that acid generation would not result in any <br />adverse impacts to local surface and ground waters, and reclamation bonding <br />requirements to cover any mitigation and/or control structures required to meet state and <br />federal water quality requirements. Although under the Construction Materials Rules such <br />an operation would not be specifically classified as a Designated Mining Operation as <br />under the Minerals Rules, the Division is still obligated to prevent acid mine drainage and <br />protect water quality from construction material mines in a similar fashion. <br />Under Construction Rules 3 and 6, the applicant cannot receive a permit until it assures <br />the Division/Board that "all refuse and acid-forming or toxic producing materials... shall <br />be handled and disposed of in a manner that will... protect the drainage system from <br />pollution." 3.1.5, see also 34-32.5-116(4); Rule 6.3.3. Without an analysis of the <br />potential for such materials to create such conditions, an applicant cannot meet these <br />requirements. Due to the likelihood that drainage from the project area will reach both <br />surface and ground waters, detailed water quality protection plans for these resources <br />must be forthcoming from the applicant prior to permitting. It should be noted that these <br />requirements are mandatory if there is a potential for any acid or toxic-forming materials <br />to occur on site -they do not become mandatory only if such formation is likely. <br />It does not appear at the present time that the applicant has provided the required <br />baseline studies of surface and ground waters, acid mine production analysis (if pyrite is <br />present), and operational and reclamation features that will protect surface and ground <br />waters from pollution. A complete review of the sources and pathways for any <br />contaminants to reach surface and/or ground waters must be conducted. Until all of this <br />information is forthcoming, the application is incomplete and cannot be approved. <br />We suggest that if field analysis determines that acid preduction is possible, then <br />additional static and dynamic tests should be conducted to more fully ascertain the <br />potential for acid production. Proper attention should be made to ensure that testing is <br />done under conditions which include the presence of thiobacillus ferroxidans and that <br />short-term neutralization reactions in the sample do not skew the results towards an <br />overly optimistic acid neutralization/production ratio. In any event, the Division should <br />not complete its review of the application until all long-term kinetic and batch tests have <br />been completed (i.e., at least 20 weeks). <br />Another important concern regards the potential for the local clay to release Phos horns <br />(primarily via sediments) to the Arkansas River system. Much of the clay in Colorado does <br />contain phosphorous. Eutrophication of reservoirs and lakes in the system is a serious <br />
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