2009-03-20_INSPECTION - M1979187

• Permit No: M1979187
• IBM Index Class Name: INSPECTION
• Doc Date: 3/20/2009
• Doc Name: Follow-up on unresolved problem
• From: DRMS
• To: Morrow & Sons, Inc.
• Inspection Date: 8/15/2006
• Email Name: PSH
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Depart new of Natural Resources
1313 Sherman St., Room 215
Denver. Colorado 80203
Phone: [phone]
FAX: [phone]

MINERALS PROGRAIvPOLICY MEMO 1
To: Minerals Staff '
From: HBH --''
Date: Ap-618 2005 AW /' .
RE: Oil and Fuel Spill Containment Structures
COLORADO
DIVISION OF
MINERALS
GEOLOGY
1111CIANAYION. PORN Ina
SAPITY.f CI[NCr
Bill owerr
Governor
Rumil Geroge
Executive Director
Ronald W. Carrany
Division Director
t??tcW f -murce T:,r--c
Purpose:
This Policy provides guidance to Operators and Staff concerning the protection of ground water
from the loss of containment of petroleum products at mine sites. This Policy stresses the need
for the Operator's reclamation bond to be sufficient for the removal of storage facilities, their
contents, and spill containment structures. It is not enforceable, unless its provisions, in whole
or in part, are incorporated into a Mined Land Reclamation Board permit through the permitting
or permit revision process.
The Minerals Program relies on other agencies' standards and design requirements for spill
containment structures to prevent spills and/or releases of oil and fuel products (see 40 CFR 112
et al.). Such agencies include the Environmental Protection Agency, relevant agencies of the
Colorado Department of Public Health and the Environment, the State Oil Inspector, and other
appropriate Federal, State or local government agencies. Even though the Minerals Program
relies on other agencies' standards and design criteria, the Minerals Program has a separate
statutory responsibility to protect groundwater quality (see Senate Bill 89-181). In determining
when one should report a spill to DMG, the Operator should rely on the agency whose reporting
criteria have die iowesfreportable spill threshold.- DMG will determine if that amount, given
site-specific circumstances, requires further actions to protect ground water quality.
Objective:
The intent of the containment structure(s) shall be to minimize the loss of oils and fuels outside
of the approved containment to ground water systems in the event of tank, drum, or delivery
system failure, or spillage from any source in excess of reporting amounts set by other Federal,
State, or local governments with authority for such matters. Even though a Spill Prevention
Control and Countermeasure (SPCC) plan may be required at a mine or prospecting site for the
protection of surface water quality by the Department of Public Health and the Environment,
Water Quality Control Division, the Office should only consider such structures where there is a
need to protect ground water quality. Containment capacity shall be sufficient to contain oils
and fuels with sufficient freeboard to contain a precipitation event, as specified by applicable
Federal, State or local government regulations.
Office of office of Colorado
Mined Larrd Reclamation Active and Inactive Mines Geological Survey