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" ASPHALT <br />SPECIALTIES CO. <br />10100 Dallas St. • Henderson, C080640 • (303) 289 -8555 • Fax: (720) 289 -7707 <br />October 23, 2014 RiecElv <br />Mr. Tyler O'Donnell <br />Environmental Protection Specialist 'CT 2 $ 201¢ <br />Colorado Div. of Reclamation, Mining and Safety <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />D1V1S101V 0', <br />MlN/NGAIVD s� AION <br />RE: Responses to Preliminary Adequacy Review Comments for Technical Revision 2 (TR -02), <br />Speer Mining Resource, DRMS Permit No. M- 1983 -176 <br />Dear Mr. O'Donnell: <br />Follows are our responses to your preliminary adequacy review comments. They are presented in <br />the order as received from you in your correspondence of September 23, 2014: <br />ASCI will commit to monitoring weed infestation on the entire site at the end of the <br />month of May and in the month of August of each year. This schedule was provided to us <br />from the weed control company who did the work for us earlier this month on the site. If <br />conditions warrant, further spraying will be performed after these assessments to control <br />local infestations. These activities will be reported in the annual report (due December of <br />each year). Attachment A contains an invoice for the work performed by Weed <br />Wranglers earlier this month and photo documentation of that work. <br />2. The CDPS permit for this site is only required due to the site still having a DRMS permit. <br />The CDPHE permit required for this site is a stormwater permit only, as this site no <br />longer produces product wash waters or mine dewatering water from gravel mining and <br />production which would require a discharge permit if mine and product wash waters were <br />to enter the South Platte River. We are under the auspices of CDPHE for water quality <br />monitoring due to the inert landfill and must perform groundwater sampling at upgradient <br />and downgradient wells. The trench to the South Platte River from the pond acts as a <br />simple "pass through" of clean groundwater from the current East Boundary Trench <br />(future Phase 1 French Drain) to the river. Attachment 2 contains a portion of recent <br />correspondence to CDPHE explaining the situation at the Speer site. <br />3. The US Army Corps of Engineers ( "USCOE ") no longer has jurisdiction on this portion <br />of the South Platte River for flood control and all jurisdiction is with the UDFCD. There <br />was no communication with UDFCD for this trench as the trench was quickly excavated <br />as part of an attempt to alleviate the upgradient rise in groundwater and flooding of the <br />Kirby basement, not realizing that the upgradient groundwater rise was more due to the <br />