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.- - • ~ iii iiiiiiiiuiiiiii, RECEIVED FE8 1 ~ 9S98 Division of Minerals 8 Geology Mr. Michael B. Long Division of Minerals Department of Natural 1313 Sherman St, Roo Denver, CO 80203 Dear Mike, and Geology Resources m 215 February 17, 1998 Thank you for taking the time to discuss some of the environmental concerns with the proposed Agile Stone System Parkdale Project (112 Permit application, M-97-054). As we indicated, Ciean Water Action, and Colorado Trout Unlimited remain concerned over the projects potential impacts on both water quality and water quantity. Unless the following issues are adequately addressed by Agile, we believe that the project ought not to be permitted. It is our understanding that there may be a substantial amount of pyrite in the area. If it is true that metallic sulfides are present in the rock and soil, then the potential for acid generation from these materials would require considerable pre- project analysis of baseline conditions, detailed assurances that acid generation would not result in any adverse impacts to local surface and ground waters, and reclamation bonding requirements to cover any mitigation and/or control structures required ~o meet state and federal water quality requirements. Although under the Construction Materials Rules such an operation would not be specifically classified as a Designated Mining Operation as under the Minerals Rules, the Division is still obligated to prevent acid mine drainage and protect water quality from construction material mines in a similar fashion. Under Construction Rules 3 and 6, the applicant cannot receive a permit until it ass~.tres the Division/Bo4rd that "ail refuse and acid-forming or toxic producing materials... shall be handled and disposed of in a manner that will... protect the drainage system from pollution." 3.1.5, see also 34-32.5-116(4); Rule 6.3.3. without an analysis of the potential for such materials to create such conditions, an applicant cannot meet these requirements. Due to the likelihood that drainage from the project area will reach both surface and ground water, detailed water quality protection plans for these resources must be forthcoming from the applicant prior to permitting. It should be noted that these requirements are mandatory if there is a potential for any acid or toxic-forming materials to occur on site--they do not become mandatory only if such formation is likely.