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t~- <br />1 <br />~~ <br />• <br />III IIIIIIIIIIIIIIII <br />sss <br />~~ Cripple Creek & Victor Gold Mining Company <br />dUN 16 1995 <br />A J01n1 Venture -Pikes Peak Mining company Manage <br />PO. Box 191, 2755 State Highway 67, Victor, Colorado 80860 <br />~~ (719)689-2977 <br />FAX (719) 6893254 <br />June 15, 1995 <br />RECEIVED <br />Mr. Berhan Keffelew <br />Environmental Protection Specialist <br />Colorado Department of Natural Resources <br />Division of Mines and Geology <br />Office of Mined Land Reclamation <br />1313 Sherman Street, Room 215 <br />Denver, Colorado 80203 <br />C11VI61bH W NlI6tlfGtD a c~tltlltlgy <br />Reference: Cresson Project• Permit M-80-244: Use of Detoxified Pad Materials -Pad 3. <br />Response to OMLR concerns related to concentrations of nitrate and sulfate. <br />Dear Mr. Keffelew: <br />Yesterday you voiced concern that use of the Pad 3 materials could potentially adversely impact <br />ground water quality. Your concerns were related specifically to nitrate and sulfate <br />concentrations in comparison to drinking water standards and criteria. First, we wish to point <br />out that the ground water in the vicinity of the Cresson Project is not a domestic drinking water <br />source. Thus, drinking water standards and criteria should not apply. The neighboring towns <br />of Cripple Creek, Victor, and Gold Fields rely on surface water sources not potentially <br />influenced by the Cresson Project for domestic water. <br />However, even if such standards and criteria did apply, the limited extent and intended use <br />should not raise any concerns for ground water quality. From a mass balance standpoint, over <br />50% of the recharge to an aquifer would have to pass through the Pad 3 material before drinking <br />water quality thresholds for nitrate or sulfate would be reached. While I have not spent the time <br />to compute the maximum area that could be covered by such material it is clearly obvious that <br />it is far less than 50% of any ground water hydrologic region. Furthermore, the primary use <br />of the Pad 3 material will be for roadbase on mine roads. Repeated traffic rapidly compacts the <br />surface, greatly reducing its permeability and its ability to contribute to ground water recharge. <br />To put the quantity of nitrate in the Pad 3 material into perspective, an acre of compacted Pad <br />3 material with an average depth of one foot would contain approximately 61 pounds of nitrate <br />nitrogen. Our present reclamation practices call for the application of 50 pounds of nitrogen per <br />acre (150 lbs of 33-0-0 fertilizer). Agricultural applications of nitrogen frequently exceed 50 <br />pounds of nitrogen per acre and sometimes exceed 100 pounds per acre. The quantity of <br />