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', ,•. <br />i <br />DIVISION OF MINERALS AND GEOLOGY <br />Deparrmem of Nawral Resources <br />1313 Sherman SL. Room ? 15 <br />Denver, Colorado 80203 <br />Phonc OOJI 8h6J5h7 <br />FAY: (3031 8)2-8106 <br />April 23, 1996 <br />Mr. Evan Freirich <br />Attorney at Law <br />III IIIIIIIIIIIII III ~F <br />999 <br /> <br />COLORADO <br />Post-it" Fax Note 7671 oale~,Z7_ ~o Pa°qes~ ,3 <br />7 <br />7o~/(x-/~ r // <br />/V G K From / <br />/E~iL br'QwLSb <br />Co./Deer. Co. f <br />Phone p Phone # <br />Fax # 3~_ 7 7r Fax # <br />The Broadway Suites <br />1942 Broadway, Suite 309 <br />Boulder, CO 80302 <br />II~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES <br />Roy Rome. <br />Governor <br />lames 5. Lochhead <br />E.ecwive Director <br />Michael B. Long <br />Div is ion DireUO~ <br />RE: Land Application 8yatem, Gold Ei11 Mi11, Operator: Colina Oro liolino <br />(COli), Inc., Permit No. K-94-117 <br />Dear Mr. Freirich: <br />The Division has received your facsimile letter dated April 12, 1996 <br />requesting clarification of the Division's approval of a land application <br />system at the Gold Hill Mill. The following numbered clarifications <br />correspond to the five paragraphs in your letter, and your paragraphs are <br />reprinted in italic letters. <br />1. Why does the Department not require the water to be treated prior to <br />land application? <br />Division Response: Land application of process water is typically <br />employed as an alternative to expensive and difficult water treatment <br />methodologies. Land application of process water is seen as an acceptable <br />alternative to water treatment in cases where the volume of waste process <br />water is small, and the contaminant levels in the land applied water are <br />low relative to standards applied to the various water uses. It is the <br />Division's position that the Hazel-A water at the Gold Hill Mill meets <br />these basic criteria. <br />2. I understand that ground water is contaminated to the same levels as <br />the Hazel A water, but why would you want to disperse the contamination <br />into topsoil and ground cover where repeated application will concentrate <br />the contamination? <br />Division Response: Land application of Hazel-A water at the Gold Hill <br />Mill would affect topsoil and ground cover in a manner analogous to the <br />affect that irrigation would have on topsoil and ground cover in an <br />agricultural setting. The Colorado Water Quality Control Commission has <br />established agricultural standards for metals levels in water suitable for <br />irrigation of crops usually grown in Colorado. I have enclosed a copy of <br />the agricultural standards for your review. Based on the analytical data <br />from the one sample of Hazel-A water that has been collected, this water <br />