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• Page 2 • ~ December 23, 1998 <br />Y <br />limited to those areas specified in the technical revision and depicted on the appurtenant <br />maps. <br />.; .~: <br />- 2. Closure Plan <br />~ A detailed closure plan for the CKD disposal areas must be included into the :ethnical <br />revision. The closure plan would specify the source location, physical characteristics, and <br />thickness of any capping material to be applied as well as the slope and drainage <br />characteristics of the closed disposal areas. In order to provide a concise presentation in the <br />technical revision, topsoil replacement and revegetation plans should also be included even <br />if they duplicate the information already in the approved reclamation permit for the Esoettcher <br />Quarry. The closure plan must also include provisions for post-closure ground water <br />monitoring as discussed in more detail below. <br />3. Erosion Control <br />The Colorado Land Reclamation Act for the Extraction of Construction Materials requires <br />that "surface areas of the affected land, including spoil piles, shall be stabilized and Ixotected <br />so as to effectively control erosion" (34-32,5-116(4)Q)). A description of measures to be <br />employed to control wind erosion and dust generation from CKD must be provid~:d as an <br />enforceable component of technical revision TR-03. Holnam must also describe stcrm water <br />run on and runoff characteristics of the CKD disposal site during typical and extreme rainfall <br />events and describe any stone water control, e.g. best management practices, necessary to <br />prevent "unauthorized release of pollutants to the surface drainage system" (34-32.5- <br />116(4)(c)). The description of any required run on and runoff controls must corsider the <br />CKD disposal sites not only when they are empty, but in the various stages of filling with <br />CKD and at the time of closure. <br />4. Wildlife Exoosure Assessment <br />It is stated in the "Hydrogeologic and Geochemical Assessment" report that the pond in the <br />CKD disposal area "is relatively small compared to waters preferred by most species of <br />waterfowl ° What is the approximate surface area of the pond? In addition, the; DMG is <br />concerned that even very small ponds may be utilized by puddle ducks such as m;illard and <br />teal. It is stated in the "Hydrogeologic and Geochemical Assessment" report that a report <br />would be prepared based on observations of waterfowl activity in the pond during the 1998 <br />fall migration. The DMG must be provided a copy of that report. It is stated in the wildlife <br />assessment provided by Holnam that the entire cut will be filled with CKD within two years. <br />Is this accurate? <br />The DMG has contacted Mike Sherman at the Colorado Division of Wildlife (DOW) <br />regarding this issue. He suggested that an inspection of the proposed CKD disF~osal area <br />would facilitate DOW evaluation of the potential for wildlife impacts. DMG will contact <br />Holnam during the first week of January 1999 to schedule a joint DMG/DOW inspection of <br />the site. <br />5. CKD Sampling and Analysis <br />Please describe the sampling methodologies employed to assure that the CKD samples <br />subjected to geochemical testing, as described in the "Hydrogeologic and Geochemical <br />AssessmenC report, are representative. Also, provide a sampling and analysis plan for <br />