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iii iuiiiiiiiiiiiiii <br />STATE OF COI.C~iy~yU <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanmenl of Natural Resources <br />I.S 13 Sherman SL, Room 215 r <br /> <br />Denver, Colorado 80201 I <br />~ <br /> <br />Nhnne: 13071 8661567 I <br />FAX: 13031 832~N106 <br /> DEPARTMENT OF <br /> NATURAL <br /> RESOURCES <br /> Roy Romer <br /> Governor <br />DATE: December 17, 1997 lames 5 Lochhead <br /> E.ecwive Duecmr <br /> <br />TO: Susan Burgmaier Michael B. Long <br />Divislnn Director <br />FROM: Mike Boulay h}~ <br />RE: Midterm Responses Southfield Mine; Technical Revision No. 29 (Groundwater <br />Monitoring and Mitigation Plan); Permit No. C-81-041 <br />I have reviewed EFCI's responses to questions 10, 12, and 13 regazding groundwater monitoring <br />and mitigation. I have the following minor comments. <br />10. Response accepted. EFCI provided good reasoning in their response. The loadouts aze <br />reclaimed and there is no baseline groundwater data for the loadout from which impacts <br />could be compared to and assessed. I think we want to reserve the right to monitor <br />groundwaternow or at any time if we deem it appropriate based on site inspections or other <br />data such as surface water monitoring results. They claim that all drainage from the loadout <br />goes to surface waterandisthereforemonitoredbytheircurrenthydrologicmonitoring. You <br />might want to check the last couple of AHR reviews to see if this is consistent or if any <br />anomalous data have been reported in their surface water monitoring. <br />12. It is standard protocol to purge wells prior to sampling. If the wells have sufficient water in <br />the well bore at the time of sampling to purge three well volumes prior to retrieving a sample <br />for analysis, then this should be done. As I understand their groundwater monitoring <br />program, they only have five wells at the entire site. Purging would not substantially impact <br />their cost or time required to conduct their groundwater monitoring program. There is the <br />issue of handling the discharge water. This can be easily handled by their site pond(s) or <br />dischazged directly to the surface as long as it does not contain toxic compounds or otherwise <br />considered contaminated. <br />13. Response accepted. <br />David Beny <br />