PERMFILE111139

• Permit No: M2003016
• IBM Index Class Name: Permit File
• Doc Date: 7/30/2003
• Doc Name: Second Adequacy Response
• From: Banks and Gesso LLC
• To: DMG
• Media Type: D
• Archive: No

~~ Banks and Gesso, LLC
~~
July 30, 2003
Division of Minerals and Geology
Attn: Kate Pickford
1313 Sherman Street, Room 215
Denver, CO 80203
RE: File M-2003-016; Second Adequacy Response
Ms. Pickford:
720 Kipling St.,Suite117
Lakewood, Colorado 80215
[phone]
Fax [phone]
www. banksandgesso.com
RECEIVED
JUL 3 0.1003
Division ~f Minerals and Geology
We received your second Adequacy Review letter for the above referenced
permit application, dated July 28, 2003. Your concerns are addressed below and
follow the order presented in your letter.
The Division requested that the Applicant "submit measures that will be
taken in order to contain spills related to damaged fittings on the tanks or
which occur while filling these tanks and barrels." In light of this request
regarding possible spills, berms will be constructed around the drums and
used as secondary containment. Further, the Operator commits to the
parameters of the Division's outlined stipulation.
2. In regards to water information, the Division requested that `Yhe Applicant
provide a study based on current, site-specific data." Please find the
Wright Water Engineers' Groundwater Monitoring and Mitigation Plan
enclosed. Monitoring will allow for updated, site-specific data, as
requested. The study will be reassessed after 5 quarters of monitoring.
As indicated in the attached mitigation plan, the trigger point has been
redefined as a 2-ft. drop.
The Division stated that "....the mitigation plan should specify what
mitigation measures will be incorporated during the time that the cause of
the change in groundwater level depth is being investigated; what
mitigation measures will be taken if the cause of the groundwater level
drop cannot be determined or identified solely as effects of the mining
activity; and how the cause of the groundwater level drop will be
identified." Mitigation during investigation will include cessation of mining
and/or dewatering operations, which will allow the pit to refill to pre-mining
levels and groundwater levels to rebound. We propose that the cause of
groundwater level drop be determined by an independent, third-party
water specialist, agreed upon by all parties. The agreed upon specialist
will be the one to conduct the independent investigation. If this
investigation finds that the Applicant is not responsible in any way for