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<br /> <br />~-~ S <br />((~~ r <br />VXBOW MINING, LLC -~ <br />3737 Hwy 133 P.O. Box 535 Somerset, Colorado 81434 USA Tel (970)929-5122 Fax <br />(470}929-5177 <br />March 28, 2006 <br />Mr. Joseph J. Dudash R~ .rr IVED <br />Environmental Protection Specialist M~~ 3 ~ 2~~6 <br />Division of Minerals and Geology <br />1313 Sherman St., Room 215 <br />Denver, Co. 80203 <br />Re: Terror Creek Loadout, Permit No. C-83-059 <br />Response to February 22, 2006 Midterm Permit Review <br />Dear Mr. Dudash: <br />The following information is submitted to the Division in order to respond to the cited Midterm <br />Review. In particular, we aze responding to the seven (7) Adequacy Review comments <br />presented on page 4 of the Review. <br />Item 1- Identifcation of Interests - We have reviewed the infornration found on PAP pages <br />2.03-6R through 2.03-6Ra and found modifications are necessary. To facilitate these changes, <br />please refer to the attached Minor Revision 24. <br />Item 2 -Section 2.035 -Compliance Information - We have found that this section will not <br />require an update. <br />Item 3 -Storage Tanks -Please see MR-24 for an updated page 2.05-2b providing a list of the <br />eight (8) tanks in use at Tenor Creek. Seven (7} of the tanks are steel and one (1) tank is plastic. <br />Five (5) of the tanks hold petroleum based products, two of the tanks hold a calcium chloride <br />based de-icer product and one tank is a water tank. <br />The Division's cost estimate provides for removal of seven (7) tanks of various sizes, which is <br />consistent with the number of steel tanks at Terror Creek but inconsistent with the sizes. The <br />Division's cost estimate addresses removal of sludge from six (6) tanks presumably holding <br />petroleum products. At TCC only five of the tanks hold petroleum products. Furthermore, the <br />Division assumes 3000 gallons for off site disposal of sludge from tanks which equates to an <br />average of 600 gallons from each of the five tanks. Given that two of the tanks hold only 300 <br />gallons, the Division's 3000 gallon estimate would appear high. TCC suggests using, instead, a <br />number of 1000 gallons instead of 3000 gallons for total sludge removal. <br />• Page 1 <br />