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STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />October 4, 2004 <br />COLORADO <br />D [VISION O F <br />MIN SRALS <br />GEOLOGY <br />RE CLAMATION•MININO <br />SAFETY•SCIENCE <br />Mr. John Lohr ~ Bill Owens <br />CEMEX Governor <br />Russell George <br />P.O. BOX $29 Executive Director <br />Lyons, CO 80540 Ronald w. cottony <br />Division Director <br />RE: CEMEX, Inc., Lyons Mine, Permit No. M-1 77-208 Natural Resource Trustee <br />Proposed Mitigation Plan v <br />Deaz Mr. Lohr, <br />The Division received the proposed mitigafion plan for issues related to water quality in the C-Pit of the <br />Lyons Mine, Permit No. M-1977-208. Based on CEMEX's letter and the meeting between DMG, <br />CEMEX and Banks & Gesso on September 24, 2004, the Division has the following comments: <br />Wildlife Assessment <br />The Division forwazded the Wildlife Assessment Report to the DOW and USFS for comment. The <br />Division will forwazd any commentstsuggestions that are received to CEMEX. However, during the <br />meeting the Division suggested that CEMEX develop a daily monitoring program to note the presence of <br />birds andlor wildlife in the vicinity of the pond. Frequency and reporting will be addressed once <br />comments are received by the DOW or USFS. <br />SamDline. Analysis and Reporting <br />CEMEX proposes to monitor Selenium, Chloride, Sulfate, pH and Total Dissolved Solids twice monthly <br />in the C and A pits and laboratory results will be forwazded to the Division within 10 days of receipt. <br />Technical Revision O1 (TR-Ol) required that Thallium (T'1) be measured in the C and A Pits. CEMEX is <br />required to monitor for Thallium until the Division approves removal of this pazameter in the form of a <br />revision to the permit. Until such revision is approved to eliminate this pazameter, CEMEX will need to <br />continue monitoring Thallium in the C and A pits. <br />The Division request that CEMEX also monitor the water level in the C-pit, and report the levels to the <br />Division in the same fashion as noted above. <br />CEMEX proposes monitoring the Dakota well with the same pazameters noted above on a quarterly <br />basis. Please be aware that the Division has not approved the location of the Dakota well as suitable <br />location to monitor groundwater. In addition, the Dakota well is a private well, which would limit the <br />Division's access to the site. CEMEX will need to address these issues before the Dakota well can be <br />considered the groundwater monitoring compliance point for the C-pit. <br />CEMEX proposes to sample the Boulder Feeder Canal and the St. Vrain River to establish a water <br />quality baseline upgradient of C-Pit. CEMEX proposes 6 biweekly samples to establish a water quality <br />baseline. In order to obtain a representative baseline of the seasonal fluctuations CEMEX should obtain <br />5 quarters of baseline data to measure over a full yeaz. <br />Office of Office of Colorado <br />Mined Land Reclamation Active and Inactive Mines Geological Survey <br />