2013-12-12_REVISION - M1990057 - Laserfiche WebLink

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Mr. Michael Cunningham CDRMS December 13, 2013 The Applicant has stated that samples will be collected quarterly and reported to the Division on the permit anniversary date. The Division will require the analytical results to be reported on a quarterly basis; any exceedance of the established baseline conditions must be reported to the Division in writing within 48 hours of such exceedance. For ground water sampling, the Applicant will be required to sample all parameters listed on Table 1 through 4 in Regulation 41 -Basic Standards for groundwater. Total coliform, asbestos, chlorophenal, color corrosivity, foaming agents, odor, phenol, gross alpha particle activity, and beta/photon emitters may be omitted from the sampling suite. Cyanide analysis must be included if cyanide is being used, will be used, or has ever been used historically at the site for ore processing. The Division observed drums of Cyanobrick in the mill during the inspection conducted on June 18, 2009; therefore, cyanide must be included in the sampling suite. The Water Quality Control Commission Regulations are stated in terms of free cyanide; however, the Division prefers that Operators analyze for WAD cyanide. For surface water sampling, the Applicant will be required to sample all parameters listed on Tables I through /// in Regulation 31 -Basic Standards and Methodologies for Surface Water. D.O., suspended solids, temperature, E. Coli, total residual chlorine, sulfide and asbestos may be omitted from the sampling suite. The Applicant may provide a total chromium analysis rather than separate analyses of the chromium species Cr(Ill) and Cr(VI). After a representative number of sampling events (five quarters for a DMO), and only with Division approval, operators may propose to eliminate certain analytes that repeatedly register undetectable concentrations in the analyses. Response: UMC's Environmental Sampling Procedures guidelines and analytes to be sampled will be included in the Permit Application, and is provided in this document as Attachment 1. UMC commits to reporting results to the Division quarterly and in the annual report. Measurements exceeding baseline conditions will be reported to the Division within 48 -hrs of the time the measurement was taken. Our process flowsheet does not require cyanide. Leadville Mining and Milling, Inc. (now AuRico Gold) personnel informed us that the cyanide at the site was never used in the process. They had planned to perform recovery tests using cyanide, but the plant shut down prior to the commencement of these tests. The 2 drums of Cyanobrick observed by the Division in June, 2009 were removed and properly disposed by Philips Environmental at an EPA - approved facility, following requisite chain -of- custody procedures. These drums were sealed (never opened). Therefore we do not believe that testing for cyanide is required. 2. The Applicant has stated they will use the analytical detection limits for surface and ground water samples which have been specified by the Division. The analytical detection limits must be below the regulatory limits otherwise the Division will reject the data. The Division recommends using method 200.8 (ICP -MS), which so far has been found to have adequate detection limits for all regulated parameters. Please respond.