2015-01-13_HYDROLOGY - M2012032

• Permit No: M2012032
• IBM Index Class Name: Hydrology
• Doc Date: 1/13/2015
• Doc Name: Water Document Review
• From: Greg Lewicki
• To: DRMS
• Permit Index Doc Type: Hydrology Report
• Email Name: RCO
• Media Type: D
• Archive: No

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• Greg Lewicki And Associates, PLLC
11541 Warrington Court Phone: [phone] Fax [phone]
Parker, CO USA 80138 E-Mail: info*lewicki.biz
January 9, 2015
ob Oswald � f '-
Colorado Division of Reclamation, Mining, and Safety RE Aa
691 CR 233, Suite A-2
Durango, CO 81301 JAN 13 2015
\RE: Water Document Review DIVISION OF RECLAMATION
MINING AND SAFETY
Dear Bob:
This letter is in response to the review of the water document sent to our office on Thursday
December 11th, 2014. On behalf of Fortune Revenue Silver Mines, there are a couple of points
that need to be addressed from the review. These points include the alteration of the proposed
total dissolved solids (TDS) standard as well as an issue that was discovered with two parameters
due to a greater baseline value in the deep well samples.
The water document review stated in item 9 that the background level of TDS is 186.25 mg/L. It
should be noted that that is the value of the parameter listed as "calculated"TDS. This parameter
has a value that was calculated in the laboratory based on other parameter measurements.
Because of the uncertainty in this calculation, a more accurate representation of TDS as
measured by the laboratory would be the parameter labeled "Residue, Filterable (TDS) @180C".
This parameter can be set as the background TDS concentration, and when including the 1.25
multiplication factor can be found listed in Table 3 of the water document as 212.5 mg/L. Table 4
in CDPHE Regulation Number 41 (shown below) states that for a TDS background of less than
500 mg/L, the maximum allowable TDS standard may be "400 mg/L or 1.25 times the background
level, whichever is least restrictive" [1]. The least restrictive standard according to this Agriculture
use-classification would thus be set to 400 mg/L. It is requested that this standard only apply to
the ground water wells and not the tailings due to the chemical nature of the SPLP test. In SPLP
testing, an acidic solution is added to tailings to dissolve solids, which in return increases total
dissolved solids, thus applying a TDS standard on tailings through an SPLP test is inappropriate.
TABLE 4
TDS Water Quality Standards
Background TDS Value (mg/I) Maximum Allowable TDS Concentrations
0 - 500 400 mgll or 1.25 times the background level,
whichever is least restrictive
501 - 10,000 1.25 times the background value
10,001 or greater No limit [1]
Upon further analysis of the review it was noticed that the proposed standards are being applied
to all well samples, not just the shallow wells. Although the water document methodology