REV01263

• Permit No: C1980006
• IBM Index Class Name: Revision
• Doc Date: 12/14/2006
• Doc Name: Response Review Memo
• From: Byron Walker
• To: Janet Binns
• Type & Sequence: TR22
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
Interoffice MEMORANDUM
to: Janet Binns
cc: Dan Hernandez
from: Byron G. Walker
subject: Marr, C-1980-006, ermanent Retention of Pond F
date: December 14, 2006
COLORADO
DIVISION OF
RECLAMATION
MtN[NG
- &-
SAFETY
Bill Owens
Governor
Russell George
Executive Director
Ronald W. Cottony
Division Director
Natural Resource Trustee
Janet, this memorandum is in response to a request by Dan to review the Technical Revision 22
application with regard to demonstration of compliance with the rules for permanent retention of Pond F.
The applicable rule is 4.05.9(13). Permanent impoundment documentation for Pond F is at Exhibit 42C.
Rule 4.05.9(13) Permanent Impoundments. Permanent impoundments for beneficial use of stored water
may only be authorized in accordance with applicable State law and upon the basis of the following
demonstration:
Rule 4.05.9(13)(a) The quality of the impounded water shall be suitable on a permanent basis for its
intended use('), shall meet applicable state and federal water quality standards(z) and discharge of water
from the impoundment shall meet applicable State and Federal effluent limitations(;) and shall not
degrade the quality of receiving water below applicable stream standards(4);
p)ana (z) The intended use is to support the approved posturing land uses of rangeland and wildlife habitat'
The applicable standards are for agricultural. Water quality monitoring to determine suitability (total
dissolved solids) was suspended in July of 1977'. There has been no reinstatement of such monitoring'.
The applicant states Chat there is no water quality data to compare with state or federal water quality
standards'. In 2005, pH was measured as 8.0 and electrical conductivity was measured as 200umhom/cm
or less'. There is noz applicable pH or conductivity standard, so the application would be in compliance
for pH and conductivity. There is a standard for dissolved oxygenz. As no data is presented, compliance is
not demonstrated. No information was provided in the application with regard to inorganic parameters, so
compliance is not demonstrated with regard to Table 2, Regulation No. 31, SCCR 1002-31. Total iron is
reported from 1996 and 1997. The current standard for iron is for dissolved iron. No value for dissolved
iron was presented, as well as for the other metal parameters of Table 3, Regulation No. 31 SCCR 1002-
31,thus compliance is not demonstrated.
A recommended comment to the applicant is: Rule 4.05.9(13)(a) Please acquire, and include in the
application, current water quality information of Pond F to demonstrate compliance with the
parameters of Tabie 1, 2 and 3, Regulation No. 31, SCCR1002-31.
cs) There were discharges from the pond in 2005. In 1997, discharge permit monitoring requirements were
reduced to flow, pH, and settleable solids. The applicant states in the application that discharges were in
compliance with the applicable effluent standards .
' Exhibit 42C, page 2
z SCCR1002-31, Regulation No. 31, Table I
Office of Office of
Mined Land Reclamation Active and Inactive Mines