2008-06-05_REVISION - C1992081

• Permit No: C1992081
• IBM Index Class Name: REVISION
• Doc Date: 6/5/2008
• Doc Name: Memo Regarding Groundwater Points of Compliance Determination
• From: DRMS
• To: File
• Type & Sequence: RN3
• Email Name: TAK
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
MEMO
Date: June 5, 2008
From: Tom Kaldenbach
To: File
Hayden Gulch Loadout (Permit C-92-081)
Hydrology
Re: Ground Water Points of Compliance Determination
Permit Renewal RN-03
COLORADO
D IV IS I ON OF
RECLAMATION
MINING
SAFETY
Bill Ritter, Jr.
Governor
Harris D. Sherman
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
I have reviewed the need for establishing ground water points of compliance at the Hayden Gulch
Loadout. I reviewed the operation's annual hydrology reports from 1996 through 2006,
hydrogeologic data in the permit application, and ground water well data from the Division of
Water Resources. The following text can be inserted in the Renewal Findings document.
Rule 4.05.13 requires establishment of ground water points of compliance if, in the judgement of
the Division, the operation has the potential to negatively impact the quality of ground water for
which quality standards have been established by the Water Quality Control Commission. Ground
water points of compliance are unwarranted at the Hayden Gulch Loadout, as explained below.
Alluvial Ground Water - Dry Creek alluvial ground water in the area downgradient from the main
surface disturbance of the loadout (the "specified area") can be classified as "Limited Use and
Quality" based on the natural TDS concentration consistently above 10,000 mg/1 in alluvial ground
water well HGDAL-3. Ground water classified as "Limited Use and Quality" has limitations for
only radioactive or organic pollutants. The loadout is not likely to generate significant amounts of
radioactive or organic pollutants; therefore, the operation does not have the potential to negatively
impact the quality of ground water in the Dry Creek alluvium.
Bedrock Ground Water - The loadout does not have the potential to negatively impact bedrock
ground water quality because any leachate originating from the loadout would lack sufficient
hydraulic head to significantly invade the bedrock unit underlying the area, the low-permeability
Lewis Shale. This marine shale confines aquifer units in the underlying Mesaverde Group (Scott
and Kaiser, 1994, Hydrologic Setting of the Upper Mesaverde Group, Sand Wash Basin in
Colorado Geological Survey Resource Series 30, page 63). Several hundred feet of Lewis Shale
separate the loadout from the deeper Mesaverde Group. As a loadout (rather than a mine), the
operation will have no deep excavations or deep impoundments where water could develop
significant hydraulic head. In addition, any leachate originating at the loadout would likely be of
better quality than native ground water in the Lewis Shale which has high concentrations of
dissolved solids.
cc: Dan Hernandez
Office o ane inns Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines