2003-03-31_REVISION - M1977344 (2)

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Division of Minerals and Geology March 31, 2003 Page 11 of 17 water volumes exceed operational requirements, excess will be pumped and discharged to Beaz Creek, and Holcim will apply for an NPDES permit from the Water Quality Control Division. Item No. 27 DMG: In accordance with Rule 6 Section 4.7 (2) (c), submit a brief statement or plan showing how water from runoff from disturbed areas, piled material and operating surfaces will be managed to protect against pollution of either surface or groundwater and, where applicable, control pollution in a manner that is consistent with water quality discharge permits during and after the operation. Response: Please see Holcim's responses to Items 7, 17, and 26, above. Post-reclamation, surface water pollution will be controlled by application of BMPs to minimize exposed slopes, slope length, armor stream channel/ditch sections when/if necessary, revegetation, etc. Item No. 28 DMG.• Has Holcim applied for or acquired a National Pollutant Discharge Elimination System (NPDES) permit from the Water Quality Control Division of the Colorado Department of Health and Environment for discharges to Bear Creek or the Arkansas River that may result from the mining operations in the Bear Creek drainage mining area? Response.• Please see response for Item No. 26. Item No. 29 DMG: In reviewing a Department of the Army Evaluation and Decision Document regarding your application fora 404 permit to relocate Bear Creek, it was noticed that Holcim may have plans to pump water from the Bear Creek mine area and return it to the Arkansas River. We assume that the water would be returned via lower Bear Creek. This is water that currently enters Bear Creek (between one and two cubic feet per second) in the middle and lower sections of the channel and seeps into the mine area. Please provide a thorough discussion of the hydrologic impacts that mining the Bear Creek drainage area will have on the water that presently seeps into Bear Creek in the that area. Include in your discussion whether this water will become groundwater when backfil[ing of mined areas occurs. If it will become groundwater, which the Division assumes it will, address this exhibit for section 4.7 (2) (b) and (c) and 4.7 (5). Pumping groundwater most likely would require a permit from the State Engineers Office. Please check with that office to determine whether one is required and address the need in this exhibit and in Exhibit M Also, discharging pumped water to lower Bear Creek or to the Arkansas River would most likely result in a requirement for changes to your NPDES permit. Address such a requirement in this exhibit and in Exhibit M. Response: Please see response for Item No. 26. Holcim believes that once the lower reach of the Beaz Creek watershed is mined, backfilled, and reclaimed, the water that presently flows out of the limestone Holcim Response to Amendment Adequacy Review.doc