PERMFILE47684

• Permit No: m2004044
• IBM Index Class Name: Permit File
• Doc Date: 12/24/2004
• Doc Name: Adequacy Response review
• From: DMG
• To: DMG
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Nafual Resources
1313 Sherman St., Room 215 C O L D RA D O
Denver, Colorado 80203 D I V E g 1 0 N o r
Phone: [phone] MIN &RA L S
FAX: [phone] G E O L O G Y
EECLANATION•NINING
SAEETY•f C1ENCF
December 24, 2004 '~
Bill Owens
To: Larry Ohler +~ envemer
Russell George
Executive Director
From: Berhan Keffelew /
0 ~/ 2L Ronald W. Gttany
rT T, ~ Division Dired°r
Re: Adequacy Response review Permit # M-2004 Natural Resourtt Trustee
I) As you requested I have reviewed Tetra Tech's Adequacy response dated
November 22, 2004, relating to the two EXHIBITS. Exhibit "D" Mining plan and
Exhibit "G" Water information, It appears for the most part, the operator had
addressed the concerns raised in the adequacy.
Under Exhibit'aD" Mining Plan I have the following comments.
1) Flood Control along the South Platt River falls under the Jurisdiction of
Urban Flood Drainage Control's Master Plan for the area. If I am not
mistaken, counties along the South Platt River, always adhere to the
recommendations of that Authority. That is why all development along the
South Platt River had to meet the Urban Flood Drainage ControPs Master
plan. As long as they commit to address all the concerns of that Authority, we
should not require additional commitment.
2) As to your request to provide additional measures to ensure sediment control
measures for protection of the Braniner and Brighton Ditches, since they are
man made structures with in 200 feet of affected area, they are covered In my
review, under exhibit'EG", # 2. As long as the operator has a written
agreement with both ditch owners, to mitigate damage to these structures, to
require them to provide additional sediment control structures might be a bit
redundant. Since the operator is going to get a Storm Water Discharge
permit from the CDOH&E, under the Clean Ware Act, which includes all
BMP'S, that will be utilized to minimize storm water impacts to a receiving
stream or body of waters of the United States, our concern should be to make
sure that whatever structures are placed, with in the permit area, we have
adequate warranty to cover the cost of reclamation.
Prior to the Clean Water Act requiring such a permit from all facilities, we used to
require an operator to submit a design for a specific storm event, If it was
temporary, it was fora 10 year 24 hour event. If it was permanent structure we
required, the designed structure must handle the flow from a 100 year 24 hour
event. (These design criteria were copied from the Coal Hand Book) However, since
the Clean Water Act was implemented in Early 90s, all we require is that the
operator apply and obtain a storm water permit from the CDOH&E. Ali we did was
Offim of Office of Colorado
Mined Land Reclamation Active and Inanive Mines Geological Survey
I