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: ~;~'EP-21-2000 <br />a ~_ ,.r. <br />~~9 <br />THU OB ~ 45 Att BAtdKS AND GESSO LLC FAX N0. 303 274 8329 <br />measures as part of the permitting process. OMG also asked that the Applicant <br />submit a copy of the Clean Up Completion Report upon completion of remediation <br />activities at the site. <br />Response: The Applicant has submitted a Voluntary Clean Up Plan to, and <br />received approval from, Colorado Department of Public Health and Environment, <br />Hazardous Materials and Waste Management Division. A copy of the letter <br />indicating CDPHE's approval is attached to this correspondence. Also included <br />with the letter is a copy of amendments made to the plan by the Applicant, at the <br />request of CDPHE. Lastly, the Applicant commits to submitting a Clean Up <br />Completion Report subsequent to completion of the remediation activities on the <br />site. <br />Exhibit G -Water Concerns <br />9. DMG Comment (1): The Division states that "a drop of three feet cannot be <br />considered a 'significant drop' unless the five quarters of groundwater monitoring <br />(still to be submiried) supports this decision." A request was made for the Applicant <br />to submit the data that has been gathered so far. Spec cation was also requested <br />concerning which of the five wells on the site will be used for groundwater <br />monitoring. <br />Response (1): Attached, please find the groundwater monitoring results gathered by <br />the Applicant to date. Based on Current baseline monitoring, the average quarterly <br />fluctuation in depth to groundwater of all monitoring wells has been 0.32 feet (3-7/B <br />inches). Using these statistics, the Applicant assumes that a three foot drop in <br />water levels is a reasonable threshold. 7o clarify, there are five wells located on the <br />site and all of the wells will be monitored. <br />DMG Comment (2): The Division also raised questions over the mitigation <br />measures proposed by the Applicant pertaining to drops in well water levels. The <br />Applicant was asked to identfy specific measures which would be taken, in order of <br />precedence, and to identify points at which new measures would be attempted. <br />Response (2): Specific mitigation measures, in order of precedence, are (A) a <br />recharge ditch or other infiltration structure filled with water; (l3) water trucked into <br />site or to location of wells affected by mining activity; and (C) drill affected wells <br />deeper. Each successive measure will be attempted in the event the previous <br />measure fails to restore water levels to within three feet of the baseline. <br />DMG Comment (3): Lastly, the DMG commented that the Applicant's request to be <br />permitted to expose groundwater after four quarters of groundwater monitoring is in <br />conflict with the Division's policy that five quarters of monitoring take place. The <br />Applicant was asked to commit to five quarters of groundwater monitoring before <br />groundwater is exposed at the site. <br />Response (3): The Applicant commits to exposing no groundwater until five quarters <br />of groundwater monitoring data are compiled and submitted to DMG. Five quarters <br />Of data will available in approximately January of 2001. <br />P. 03 <br />