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Memorandum to Corey Hoffmann <br />November 14, 2005 <br />• Page 14 <br />9. Proposed condition: If an exceedence of water quality standards is documented in any <br />sample of surface or ground water that can or will leave the property boundaries, upon <br />becoming aware of the test results, the Applicant shall immediately report the results to the <br />Colorado Department of Public Health and Environment by telephone. The Applicant <br />shall resample the source for the parameter(s) in violation, requesting an expedited turn <br />around time for the second sample results. Within five (5) working days of the initial <br />phone notification, the Applicant shall submit in writing to CDPHE, with a copy to the <br />Division, a copy of the sample results, and the following information: a description of the <br />water quality standards exceedence and what likely caused it; the period of noncompliance <br />with standards, including dates and times and/or the anticipated time when the discharge <br />will return to compliance; and all steps being taken to reduce, eliminate, and prevent <br />recurrence of the noncomplying discharge. <br />Board Jurisdiction: Rule 3.1.6(1)(b) requires that disturbances to quality of water in <br />surface and ground water systems shall be minimized by measures, including, but not <br />limited to, compliance with applicable federal and Colorado water laws and regulations, <br />including water quality. <br />The Applicant, in its August 19, 2005, Response to 2"d Adequacy Review comments, <br />• notes that it will monitor all on=site water holding structures for radioactivity. The <br />frequency of monitoring will initially be monthly, and the parameters to be monitored <br />and standards applied include several radioactivity parameters for which there are water <br />quality standards. The Applicant then states, "If exceedences of the standards occur for <br />three consecutive monitoring periods the Applicant will analyze the source of the <br />exceedences and remove the source rock to the quarry reclamation process." <br />Waiting for three months worth of violations of water quality standards to occur before <br />initiating a search for the source of the exceedences and implementation mitigation <br />measures is not safe or feasible and must not be allowed. Once a single water quality <br />standard exceedence is documented, appropriate response(s) should be initiated. The <br />language in the above recommended condition is based on standard language used by the <br />Colorado Department of Public Health and Environment in its permits for discharge to <br />waters of the State. <br />10. Proposed condition: The Applicant shall replace trees and shrubs impacted by mining <br />operations at a minimum 1:1 ratio with native species to emulate or improve on the wildlife <br />habitat at the site and to ensure a diverse and long-lasting vegetative cover. Sufficient <br />water shall be made available for tree and shrub watering during revegetation. All trees <br />and shrubs shall be irrigated until self-sustaining. Topsoil shall be placed from two to eight <br />inches deep, with an average of 4 inches. All areas compacted during mining shall be <br />ripped. Vegetation re-establishment on the site shall be monitored for a minimum of 5 <br />years for each phase. The reclamation bond shall contain at least $786,608 to cover the cost <br />• of revegetation. <br />LEONARD RICE ENGINEERS. INC. <br />2000 Cvv STaeEr, SUITE 300, DervveR, COLORADO 8021 1-51 1 9 • PHONE (303) 455-9589 • Fnx (303) 45501 1 5 <br />