2015-07-22_PERMIT FILE - P2015016 ‎(2)‎

• Permit No: P2015016
• IBM Index Class Name: PERMIT FILE
• Doc Date: 7/22/2015
• Doc Name: Comments
• From: Upper Clear Creek Watershed Assoc.
• To: DRMS
• Email Name: MAC
• Media Type: D
• Archive: No

Upper Clear Creek Watershed Association
P.O. Box 3058 Idaho Springs, Colorado 80452
July 22, 2015
Michael A. Cunningham
Division of Mine Reclamation and Safety
1313 Sherman St. Room 215
Denver CO 80203
Re: Santiago Mine; DRMS File No. P-2015-016
Dear Mr. Cunningham:
RECEIVED
JUL 22 2015
DIVISION OF RECLAMATION
MINING AND SAFETY
The Upper Clear Creek Watershed (UCCWA) is the 208 water quality agency in the upper
watershed. In that capacity, we have the responsibility to review activities that may affect
water quality in our area. To that end, we have reviewed the above -listed application and
this letter will share our concerns with you.
The proposed area of investigation is in and just above an area of known metal loadings in
the headwaters of Leavenworth Creek, a first -order stream that flows into South Clear
Creek. It is 3,500 ft southwest of the Watershed Protection Area of the Town of
Georgetown. The building of the Santiago mill sits on the formerly unpatented "Hazleton
mill site." Samples from the mill site contain elevated concentrations of the metals arsenic,
mercury, lead, zinc and copper, which lead to the decision of the USFS to reclaim the site.
The Waldorf mine and Wilcox [Waldorf] Tunnel, a similar mine that is about 2,500 ft
southeast of Santiago and 4,100 ft southwest of the Georgetown Watershed Protection Area
has been studied and is a high priority for remediation owing to its metal contributions to
Leavenworth Creek. The mine has metals that are documented to run into Leavenworth
Creek via surface and ground water. The Wilcox Tunnel has metal -bearing drainage that
feeds into Leavenworth Creek.
The proposed operations of "cuts, pits, tunnels, trenches, adits, drilling and blasting" will
be right above the tailings and waste of the Santiago mill area, which has recently been
closed to the public for reclamation. Furthermore, the applicant indicated he would not be
going into the Levels 3 and 4, and that underground water, if encountered, will not be
would be disturbed. And yet, he mentions "adits, drilling and blasting." Besides this
inconsistency, blasting would increase fracture porosity, which would lead to more access
of surface water to mine workings and/or mineralized rock, with potential for subsequent
acid mine drainage.
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