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Ms. Arthur <br />Page 1 2 <br />April 22, 2011 <br />working days when there is evidence of groundwater discharges exceeding applicable <br />groundwater standards. In the event groundwater exceeds the applicable standards, the <br />Division will work with the Operator to determine if additional sampling and/or mitigation is <br />required. Please commit to providing the Division with a written report within five working <br />days when there is evidence of groundwater discharges exceeding applicable groundwater <br />standards. <br />4. The Operator has proposed eliminating monitoring location CEM-001 from the water <br />sampling program. The Operator contends the Fort Hays Limestone does not meet the <br />definition of an aquifer. C.R.S. 34-32.5-116(4)(h) states disturbances to the hydrologic <br />balance of the affected land and of the surrounding area and to the quality and quantity of <br />water in surface and groundwater systems, both during and after the mining operation and <br />during reclamation, shall be minimized. The classification of a particular formation as an <br />aquifer has no bearing on the Operator's responsibility to minimize disturbances to <br />groundwater systems. The monitoring location CEM-001 is located down gradient of C-Pit <br />and continues to produce water samples. In addition, the Operator has reported fractures in <br />the bed rock transmit changes in head between the C-Pit and CEM-001. Therefore, the <br />Division believes this monitoring location should continue to be sampled on a quarterly basis <br />along with C-Pit and CEM-004. <br />5. The Operator has reported monitoring location CEM-005 has been abandoned due to the <br />collapse of the well. Monitoring location CEM-005 was the former compliance point for the <br />water monitoring program. Rule 3.1.7(6)(a) requires the Operator to establish one or more <br />points of compliance in order to evaluate the protection afforded groundwater quality, <br />comply with groundwater standards, or to demonstrate compliance with permit conditions <br />established by the Division to protect groundwater quality. Please identify one or more <br />compliance points to be used in the groundwater monitoring plan. <br />This concludes the Division's preliminary adequacy review of this application. Please remember <br />that the decision date for this application is April 27, 2011. As previously mentioned, if you are <br />unable to provide satisfactory responses to any inadequacies prior to this date, it will be your <br />responsibility to request an extension of time to allow for continued review of this <br />application. If there are still unresolved issues when the decision date arrives and no extension <br />has been requested, the application will be denied. <br />If you have any questions, please contact me at (303)866-3567 x8116. <br />Sincerely, <br />Michael A. Cunnin ham <br />Environmental Protection Specialist <br />CC: Tony Waldron, DRMS