PERMFILE65180

• Permit No: M1999002
• IBM Index Class Name: Permit File
• Doc Date: 4/12/1999
• Doc Name: GROUND WATER AND SURFACE WATER MONITORING PLAN
• From: DMG
• To: BLM
• Media Type: D
• Archive: No

- , iii iiiiiiiiiiiiiiii~ ~- ~
- 999
/~ STATE OF COLORADO
FRoM• DIVISION OF MINERALS AND GEOLOGY
eparimenl of natural Resources _
1313 Sherman St., Room 2I5
Denver, Cobrado BU203
Phnnr: (3031 866-35h7
FAX: [phone]-H106
April 12, 1999 /
DIVISION OF
MINERALS
GEOLOGY
RECLAMATION
MININC•SAFETY
Bill Or:ens

Mr. Paul Daggett Covernur

~ : Bureau of Land Management Greg E Watcher
Eae<~~~~.e onerlor
73544 Highway 64 htic hacl B Long
Meeker, CO 81641 Drtiilon Director
/RE: Ground Water and Surface Water Monitoring Plan, American Soda, L.L.P., Yankee
- Gulch Minerals Project, File No. M-99-002
Dear Mr. Daggett:
On April 8, 1999, the Colorado Division of Minerals and Geology (DMG) received a copy of the draft
Ground Water and Surface Water Monitoring Plan prepared by Agapito Associates for American Soda.
It was indicated to DMG that comments on the draft plan needed to be provided to BLM by April l2,
1999. Given this short review and comment time frame, DMG is unable to list or comment on all of
the permitting issues that may be required to incorporate the monitoring plan into the State reclamation
permit for this mining operation. However, the following issues are discussed in an effort to assure
that the DMG and BLM requirements will be conformable and will minimize the monitoring and
reporting difficulties for both the agencies and the mine operator.
Essentially, the proposed plan addresses the issues discussed at the meeting held at the Meeker BLM
office on March 25, 1999. The following issues should be addressed in the final version of the plan.
American Soda should provide a table listing the maximum practical quan[i[ation limits (PQLs)
that will be applied to the laboratory analysis of the parameters in Tables 2 and 3 of the draft
plan. For those parameters listed in Tables 1-3 of the Colorado Basic Standards for Ground
Water (5 CCR 1002-41), the PQLs should be less than the applicable numeric standard.
2. Corrective actions are specified in the draft plan to be taken if any of the ground water
monitoring parameters or the water table elevation at the dissolution surface aze measured at
more than three standard deviations above baseline or ambient levels. The DMG submits that it
is premature to determine action levels (e.g., three standard deviations) before collection and
analysis of the ambient quality and water table data. Typically, the DMG will evaluate the
ambient data once it has been assembled and use this information to establish numeric
protection levels and practice-based permit conditions protective of ground water.
3. The micropurge volumes specified in the draft plan are one'tubing volume. It is assumed that
the volume of the bladder pump will be included in this calculation. Typically, some additional