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_s' <br />`w • • <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanmern of Natural Resources <br />GTOT'r nr' COLORADO <br />III IIIIIIIIIIIII III ~,~, <br />1313 Sherman 51., Room 215 <br />Denver, Colorado 80203 <br />Phone (3031 866-3567 <br />FA\:13031 R32-8106 <br />II~~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br /> <br />DATE: <br />December 11, 1997 Roy Romer <br />eovernnr <br /> ' lames 5. Lochheul <br /> <br />TO: <br />Gary Curtiss Executive DneUOr <br />Michael s. Enna; <br /> <br />FROM: <br />Allen Sorenson ~ Divivnn Dueclor <br />RE: Conceptual Reclamation Plan for the Gold Hill Mill, Colina Oro Molino, <br /> Inc., Permit No. M-9A-117 <br />I have reviewed the above referenced document prepared by Walsh Environmental for Colina <br />Oro Molino and submitted on 10/10/97. I have also reviewed your draft adequacy letter, and <br />offer the following comments. <br />1. In section 2 of the Conceptual Reclamation Plan, it is stated that the Gold Hill Mill is set <br />up to use drainage water from the Hazel-A adit as process water. In fact, in order to use the <br />Hazel-A water, the operator would have to obtain a well permit from the Office of the State <br />Engineer. Since the operator is consuming Hazel-A water continuously through evaporation, <br />even when the mill is not running, a well permit must be obtained. The Division raised this as an <br />issue in an inspection report dated 8/5/96. In response, the operator applied for a well permit on <br />9/1 1/96. A check of the State Engineer's records indicates that the well permit application was <br />found inadequate and was retnred to the operator on 9/30/96, with no subsequent action taken <br />by the operator to obtain the permit. As such, the operator is currently consuming water from an <br />unpermitted well (the Hazel-A adit).. <br />2. In section 3.l of the Conceptual Reclamation Plan, i[ is stated that operation and <br />maintenance of the Hazel-A adit will be the responsibility of the owner once it has been pumped <br />down and all Franklin equipment and piping are removed. [t was the operator, Colina Oro <br />Molino, that plumbed the Hazel-A into the mill process water circuit, and it was Colina Oro <br />Molino that inadvertently sluiced tailing into the Hazel-A. It was these actions that created the <br />requirement for a CDPS permit to discharge ground water collected in the adit. In accordance <br />with Water Quality Control Division and Environmental Protection Agency policy, the ground <br />water discharged from the Hazel-A adit prior to Colino's actions would have been a low priority <br />for CDPS permitting. As such, it is the operator's responsibility, not the landowner's, to <br />maintain the Hazel-A in azero-discharge configuration or to assure that any discharges are in <br />compliance with the Water Quality Control Act. If the operator discommects the decant line that <br />plumbs the pond to the Hazel-A, and if the operator demonstrates to the satisfaction of the <br />