Laserfiche WebLink
STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Na[ural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />October 13, 2004 <br />Mr. Ed Cooley / <br />American Soda, LLP (~ <br />2717 County Road 215 <br />Parachute, CO 81635 <br />v <br />7/ <br />RE: American Soda, LLP, Yankee Gulch Minerals Project, Permit No. M-1999-002 <br />TR-04; Adequacy Letter Clarification <br />Deaz Mr. Cooley, <br />This letter asks for clarification on data supporting Technical Revision 04 (TR-04). <br />COLORADO <br />DIVISION O F <br />MINERALS <br />GEOLOGY <br />0.ECLANATION•NININC <br />SAFETY•SCIENCE <br />Bill Owens <br />Governor <br />Russell George <br />Executive DireROr <br />Ronald W. Cottony <br />Division Director <br />Natural Resource Trustee <br />Some of the data collected during the baseline period reflect an unstable baseline. Some <br />parameters increased over the baseline period while others decreased and still others fluctuated. <br />Despite those featlrres, the Division still established Numeric Protection Levels (NFL's) or Eazly <br />Warning Indicators (EWI's). Re-visiting those decisions in light of data collected during the <br />production era, we aze not sure that baseline has been accurately chazacterized. Except for what <br />might be considered seasonal fluctuations in some shallow groundwater wells, it is not clear why <br />baseline values would show any trends at all. American Soda will need to explain the baseline <br />data, and interpret what occurred during that period to reflect such different numbers than in the <br />production phase. <br />2. The Division recommends that American Soda continue monitoring all regulated parameters, <br />including dissolved metals, sulfate, nitrogen compounds, etc. If you can demonstrate strong <br />dependant trends between several parameters, it would be acceptable to monitor a smaller set of <br />indicator parameters. In that regard, you should be prepazed to return to a more rigorous <br />monitoring program if changes emerge in the limited monitoring data sets. <br />3. The Division recommends that American Soda continue monitoring all of the major cations and <br />anions. This will allow you to evaluate hydrochemical changes that maybe caused by <br />groundwater mixing or geochemical reactions. <br />Please be advised that Division's decision due date is set for October 18, 2004. If you feel more time is <br />needed to complete your reply, the Division can grant an extension to the decision date. This will be <br />done upon receipt of a written waiver of your right to a decision by October 18, 2004 and request for <br />additional time. This must be received no later than the deadline date. If you have any questions, please <br />contact me at (303) 866-4943. <br />Environmental Protection <br />cc: vCazl Mount; DMG <br />~~llen Sorenson; DMG. <br />Office of <br />Mined Land Reclamation <br />Office of <br />Active and Inactive Mines <br />Colorado <br />Geological Survey <br />