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III IIIIIIIIIIIIIIII <br />999 <br />~ • <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />April 21, 2000 <br />To: Tom Schreiner <br />From: Harry Posey4~~'~C/' <br />Subject: Adequacy Issues: Lafarge Inc., Tanabe Pit, M-2000-002 <br />DIVISION OF <br />MINERALS <br />GEOLOGY <br />RECLAMATION <br />MINING•SAFETY <br />Bil I Owens <br />Governor <br />Greg E. Walther <br />Executive Director <br />Michael B. Long <br />Division Director <br />This memo follows our meeting today with Laura Williams and Larry Kimmel of EPA and Pam <br />Acre ofTuttle-Applegate. This review addresses questions about groundwater chemistry, alone. <br />have not reviewed other issues such a slope stability, water rights, right of ways, etc. <br />COMMENTS <br />Several letters of concern and my review house questions about the following: <br />• mining within a contaminated aquifer; <br />• whether groundwater had been tested for contaminants including diisopropylmethyl <br />phosphonate (DIMP), methyl chloride, other volatile organic compounds, parathion, DDT, <br />marathion, atrizine, non-chlorinated hydrocarbons including ethyl benzine, and xylene. <br />• need for an NPDES discharge permit; <br />• potential for withdrawal of existing off-site groundwater contaminants into the mining site <br />through pumping. <br />The following addresses these concerns in order. <br />A. Potential eround~vater contamination. <br />On review of maps and documents prepared for EPA, it is apparent [hat the proposed operation <br />occupies an area near former and perhaps present groundwater plumes containing DIMP, and is <br />near aformerly-mapped plume containing TTCLE. DIMP in excess of 8 parts per billion (ppb) <br />existed in groundwater a few hundred feet northeast of the proposed pit as recently as 1997 in a <br />plume that has been shrinking for several years. Detectable DIMP also existed in groundwater <br />coincident with the western portion of th eproposed operation as recently as 1996; however, this <br />plume did not appear in 1997 reports. TTCLE was reported as recently as 1996 in an area <br />approximately '/< mile southwest of the proposed site, but apparently has not been reported since. <br />Except for D[MP and TTCLE, according to Williams and Kimmel, none of the other <br />contaminants named in letters to the Division have been identified within or in the near vicinity <br />of the proposed operation. Because groundwater is being pumped from several locations on the <br />