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f III IIIIIIIII IIII III <br />999 <br />• • <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman 51., Room 215 <br />Denver, Colorado 80203 <br />Phone 003) 866-3567 <br />FA%:003) 832-8106 <br />April 11, 2000 <br />To: Tom Schreiner <br />Carl Mount <br />From: Harry Posey <br />Subject: Partial Review: Tanabe Pit 112 Permit Application; M-2000-002 <br />This review is preliminary and subject to additional comments and refinement based on <br />information not received or perhaps not yet developed or available. <br />DIVISION OF <br />MINERALS <br />GEOLOGY <br />0.EC LAMATION <br />MINING•SAFETY <br />&II Owens <br />Governor <br />Greg E. Watcher <br />Enecutivc Director <br />Michael 8. Long <br />Division Di~edor <br />As indicated on various maps provided by the CDPHE and objectors, the proposed pit transects <br />an azea identified in 1994 as having elevated concentrations of diisopropylmethyl-phosphonate <br />(DIMP). The term "elevated concentrations," in this case, indicates concentrations in excess of 8 <br />parts per billion - 8 ppb -which is the regulatory limit for drinking water. <br />[n addition, the maps indicate that the proposed gravel excavation will abut or will come within a <br />few hundred feet of the >8 ppb DIMP plume as identified in 1997. <br />Other contaminants from the Rocky Mountain Arsenal (RMA) are named as being present in the <br />area, but aze not located on the maps provided. <br />Based on the information from the 1994 and 1997 DIMP iso-concentration contour maps, it <br />appeazs possible that the proposed pit could intersect groundwater with elevated levels of DIMP, <br />and perhaps other contaminants. Moreover, it appears that groundwater pumping, which will be <br />necessary to effect dry mining, would lower water levels, locally, possibly drawing plume <br />contaminants into the pit or into the dewatering trenches. This observation is based on the <br />undocumented notion that the contaminant plumes from the RMA lie in the same shallow <br />alluvial aquifer that is proposed for mining, and on the further undocumented assumption that <br />current levels of contaminants are above drinking water standazds. If it is shown that the <br />contaminant plumes lie in aquifers deeper than the mining zone, then these concerns could be <br />moot. <br />I have contacted persons familiar with the current situation at the RMA and off site, and DMG <br />will meet with them for a briefing on local conditions as soon as possible. As the decision date <br />for this permit is fast approaching, and because the Division was apprised of the possible <br />groundwater contaminant conditions only recently, then owing to the Division's lack of <br />