PERMFILE124652

• Permit No: M2002111
• IBM Index Class Name: Permit File
• Doc Date: 9/24/2003
• Doc Name: Adequacy Review
• From: DMG
• To: Elam Construction Inc
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY /
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
September 24, 2003 I~
DIYI SION Or;
MINERALSi
GEOLOGY
RECLAMATION
MINING•SAFETY
- ~ Bill Owens
Mr. Harold Elam , / covemnr
Elam Construction, Inc V Greg E. Walther
1225 $OUth 7t6 Street Executive Director
Ronald W. Cattany .
Grand Juriction, Colorado 81501 / Ac[ing Division Director
RE: Gilsonite Gravel Pit FIIe.No. M-2002-111, 112c Application Additional Adequacy Review `~
Dear Mr. Elam:
DMG has identified several additional adequacy comments relating to your application fora 112c
Construction Materials Permit, File No..M-2002-1 1 1 for the Gilsonite Gravel Pit. The application
cannot be approved until these additional issues are adequately addressed. Please submit a .
response to the following issues as soon as possible, but no later than October 10, 2003 so DMG
staff have adequate time to review the responses prior to the decision due date set for October 20,
2003, If you cannot respond by October 10; 2003, please submit a written request for extension
of the decision date. If your response, or an extension request, are not received by October 10,
2003 this application may be denied.
Additionally, the reclamation cost estimate, calculated by DMG is enclosed. The amount is based
on reclamation after excavation of Phase 3. It includes some details not yet found in the permit
application, but were discussed and clarified with Greg Lewicki in recent phone conversations.
Please review these calculations carefully and notify DMG of any calculation errors identified.
ADEQUACY ISSUES
Exhibit G -Water Information
1. Because of the measures proposed to keep the hydrocarbon contamination plumes
stationary during and after the mining process, DMG will not require a specific groundwater
treatment plan for a situation where contamination is detected in the pit, trenches or
sediment pond las was required in item no. 44 of the second adequacy review).
However, Elam must either demonstrate-that the proposed amount of head in the trenches
during mining is adequate to keep the contamination plumes in place, but is not excessive
causing the contamination plumes to migrate north, east or west; or submit a detailed
monitoring plan designed to identify the optima! water level to be maintained in the
trenches. DMG recommends using the least amount of head in the trench as is necessary
to minimize the affects of dewatering the pit.
2. Please submit a groundwater monitoring plan in compliance with Rule 3.1.7. The plan must
include the groundwater quality standards that are applicable to this site, as specified by