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• data, sediment pond discharge weir and riprap revetment analysis was done. This analysis was <br />based on design guidance provided by the Federal Highway Administration Ifvdraulic <br />Engineering Circulars HEC-11 & HEC-15 and the Urban Drainage & Flood Control Criteria. <br />Additionally, more specific sediment pond construction specifications have been provided. <br />Exhibits C, E, and T have been revised with this information. <br />f A stormwater permit is required from the Water Quality Control Division, see SWMP application <br />attached as an appendix to Exhibit F and the SWMP itself attached in the appendix of Exhibit C. <br />22. Exhibit T has been revised to more accurately reflect that the Tailings Impoundment and Water Holding <br />Pond are "liquid containment systeins". Because of adding a shelter over the Crusher Feed Pile (see Item <br />#4 of this letter), this specific structure is no longer considered a "liquid containment system". Exhibit T <br />6.4.20(13)(a) has been revised. Water balance, in the context of water rights, will be addressed in Item <br />#26 of this letter. <br />23. The Tailings Impoundment and Water Holding Pond liner will require inspections by DRMS. Exact dates <br />of construction are not immediately available. However, the DRMS has stated that the Operator shall <br />"provide ten days notice prior to commencement of geosynthetics installation ... DRMS will typically <br />inspect ground preparation prior to any geosyntlietics being installed, and will be onsite during at least <br />some of the HDPE seaming operations. Testing of all HDPE seams is required during (concurrent with) <br />installation. Both destructive and non-destructive tests are required." Venture Resources commits to <br />adhering to these notice requirements before liner installation. See revised Exhibit T, 6.4.20(15). <br />24. A water balance analysis has been provided in the revised Exhibit C. The effects of evapotranspiration <br />have been considered in revised Exhibit D to determine that installation of a final cap/cover to limit <br />precipitation infiltration will not be necessary. <br />• 25. The tailings disposal pipelines and process water supply & recycle pipelines shall be specified to be <br />constructed using a double-walled containment arrangement. A commitment to drain the pipelines when <br />the site in unmanned has also been provided. Venture Resources acknowledges that the pipelines are <br />environmental protection facilities subject to Rule 8 reporting requirements and has addressed this along <br />with a leak containment plan. Refer to revised Exhibit: C, E and T. <br />26. There is the potential for rainwater to become co-mingled with process water in the lined Tailings <br />Impoundrent and Water Storage Pond. Because no Industrial Discharge Permit is in place, there are no <br />provisions to treat this co-mingled water for release. To compensate for this, Venture Resources will be <br />purchasing a Temporarv Substitution Water Plan contract from the Clear Creek County Water Bank. This <br />is in progress and is not available at the time of re-submittal. A copy of this contract will be provided as <br />an appendix to a revised Exhibit C. <br />27. Concerning Clear Creek County's comment letter of December 16, 2009 <br />a. 'Venture Resources agrees that the storage or parking of equipment on public roadways in not <br />permitted. Exhibit C - 6.3.3(1)(g) and Exhibit L have been revised with a commitment <br />addressing the same. <br />b. Absolutely no road segments are being eliminated as part of this proposed operation. There is a <br />pre-existing road segment that crosses the pre-existing waste rock dump and the course of this <br />road will be preserved. See revised Exhibit B - 6.3.2(b) and Exhibit L for an explanation. <br />c. Concerning portable toilet facilities; Venture Resources has already executed with Clear Creek <br />Comity Environmental Health Department a "Clear Creek County Construction Site Sanitation <br />Agreement Form". This form acknowledges that a portable toilet adequately address the <br />requirements set forth in the Clear Creek County Individual Sewage Disposal System regulations, <br />namely: <br />. "The owner of any structure or land site where people live, work or congregate <br />shall insure that the structure or land site contains adequate, convenient and <br />Page 5 of 7