PERMFILE123465

• Permit No: M2003016
• IBM Index Class Name: Permit File
• Doc Date: 8/6/2003
• Doc Name: Third Adequacy Response
• From: Banks and Gesso LLC
• To: DMG
• Media Type: D
• Archive: No

~~ Banks and Gesso, LLC
~~
August 4, 2003
Division of Minerals and Geology
Attn: Kate Pickford
1313 Sherman Street, Room 215
Denver, CO 80203
720 Kipling St.,Suite117
Lakewood, Colorado 80215
[phone]
RECEIVE ax (banksandg sso.com
AUG 0 62003
Division of Minerals and Gealo'y
RE: Heit Sand and Gravel Mine - M-2003-016; Third Adequacy Response
Ms. Pickford:
We are in receipt of the Division's Third Adequacy Review letter, dated August 1, 2003,
in relation to the above referenced Regular 112 Permit application. Our responses to
these concerns follow in the same order as presented in your letter.
Rule 6.4.4 Exhibit D - Minino Plan
Oil products stored on site, whether in drums or tanks, will be stored within a
lined earthen berm or other secondary containment structure capable of
containing minor leaks or spills during filling (such as a spill deck or drum storage
hut) and preventing soil contamination. Containment berms will be lined with a
heavy-duty liner (such as visqueen or PVC) designed to prevent soil and water
contamination from oil spills.
Any oil tank with a capacity over 660 gallons will be permitted with the Colorado
Division of OiI and Public Safety, and will be constructed, contained, and
maintained as required by the Colorado Petroleum Storage Tank Regulations (7
C.C.R. 1101-14). If the total above ground storage of oil products exceeds 1320
gallons (excluding containers less than 55 gallons in capacity), a Spill Prevention
Control and Countermeasure (SPCC) Plan will be developed and implemented
as required by State and Federal regulations.
2. To make absolutely clear, the slurry wall will be installed around the mining limits
prior to any dewatering activities at the site. No dewatering activities will take
place until the slurry wall has been completely installed around the perimeter of
the mine limits, as shown on the maps previously submitted to the Division.
3. The French drain system will be installed within two weeks of the completion of
slurry wall installation. With respect to the requirement that a Technical Revision
be submitted to the Division for review of design specifications for the French
drain, there is question as to the need for this. According to the Construction
Rules and Regulations Rule 1.1(49), a Technical Revision is "a change in the
permit or an application, which does not have more than a minor effect upon the
approved or proposed Reclamation Plan." We do not believe that a review of the