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STATE OF COLORADO <br /> DIVISION OF MINERALS AND GEOLOGY . <br /> Department of Natural Resources Writ <br /> 1 31 3 Sherman St., Room 215 <br /> Denver,Colorado 80203 <br /> Phone:(303)866-3567 <br /> FAX-(303)832-8106 <br /> DEPARTMENT OF <br /> NATURAL <br /> November 30, 1998 RESOURCES <br /> Roy Romer <br /> Governor <br /> MEMO James S.Lochhead <br /> Executive Director <br /> TO: Cheryl Linden Michael B.Long <br /> Drvison Director <br /> FROM: Steve Renner <br /> --- <br /> RE: Mid-Continent Resources NPDES Permit Renewal Application <br /> As requested, I have reviewed the NPDES permit renewal application submitted by Mid- <br /> Continent Resources to Water Quality Control Division. The following comments pertain to the <br /> submittal. <br /> Cover Letter Page 2, and recurring throughout the document: In many places throughout the <br /> document, Mid-Continent Resources (MCR) states that Minerals and Geology (DMG) reclaimed <br /> a number of access or haul roads, and as a result of this activity, the ponds located near the upper <br /> reaches of these roads are no longer accessible. Minerals and Geology accomplished reclamation <br /> of Roads E, F and G, which provide access to Mines 3 and 5, and of the uppermost one half mile <br /> of the access road to Mines 1 and 2 in 1996. Reclamation construction consisted of removal of <br /> virtually all road drainage culverts, changing the slope of the road from the inside to the outside, <br /> construction of numerous water bars, deep ripping of the road remnant, and revegetation. The <br /> mines located at the top of these roads are accessible by horse back, by foot, by bicycle and by all <br /> terrain vehicle. Mid-Continent employees, consultants, and contractors have accessed these <br /> mines via all terrain vehicle subsequent to reclamation being accomplished. Furthermore, <br /> contractors to Mid-Continent accessed Mines 3 and 5 vicinities via the reclaimed roads using a <br /> large track loader (similar to a bull dozer) in 1997. <br /> Permit Application Form, Page 3, Flow Measurement: It is possible that some of the flow from <br /> the 016 discharge point is flowing around, rather than through, the parshall flume located below <br /> the discharge point. <br /> Permit Application Form, Page 3, Land Application: Minerals and Geology, the agency <br /> accomplishing reclamation of the site, has no plans to land apply discharges from the Rock <br /> Tunnel. Minerals and Geology has planned to construct a channel to convey the flow from the <br /> Rock Tunnel to Dutch Creek. Water Quality Control Division was consulted about this concept <br /> in 1996. Issues regarding WET testing were not resolved between Water Quality and Mid- <br /> Continent, therefore, diversion of the flow to Dutch Creek was not undertaken at that time. The <br />