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2018-06-20_REVISION - M1977300
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2018-06-20_REVISION - M1977300
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Entry Properties
Last modified
7/6/2018 1:13:10 PM
Creation date
6/20/2018 3:28:27 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
Revision
Doc Date
6/20/2018
Doc Name
Adequacy Review Response
From
Colorado Legacy Land, LLC
To
DRMS
Type & Sequence
TR26
Email Name
MAC
Media Type
D
Archive
No
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RESPONSE TO COMMENT MATRIX <br />PAGE 2 OF 3 <br />Document Title: Technical Revision 26, Schwartzwalder Mine, Golden Colorado <br />Submission Date: May 9, 2018 <br />Reviewer(s): Michael Cunningham Environmental Protection Specialist <br />Colorado Division of Reclamation, Mining and Safety, Department of Natural Resources <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Review Date: May 30, 2018 <br />Comment Comment Response to Comment cartridge filters and RO membranes which were analyzed were associated with the old water treatment plant (OWTP). The Operator has since constructed a new water treatment plant (NWTP). Have there been any changes in the design and operation of the NWTP which could result in increased Uranium and Radium-226 levels in the cartridge filters and RO membranes? In addition, how will the operator ensure the cartridge filters and RO membranes continue to fall below the threshold for regulated source materials? <br />are expected to be encountered during steady-state operations. There have not been any changes to the design or operation of the NWTP which have resulted in increased Uranium and Radium-226 levels in the cartridge filters and RO membranes. To confirm this, the cartridge filters and membranes can be sampled annually. <br />4 As indicated above, the Operator has stated the cartridge filters and RO membranes are exempt from CDPHE’s radiation protection regulations. Please specify if the Operator’s Radioactive Materials License addresses the disposal of solid wastes generated from the water treatment process. In addition, specify if the Hazardous Materials and Waste Management Division was consulted regarding the disposal of cartridge filters and RO membranes at the mine site. <br />The Radioactive Materials License CO-396-06 (RML) addresses the disposal of the solid wastes generated from the water treatment process by reference in License Condition 15.B. In early 2017, the licensee requested a modification of the Radioactive Materials License from CDPHE to allow for the transition from the Old Water Treatment Plant to the New Water Treatment Plant. As part of the review, CDPHE asked specifically about the cartridge filters and RO membranes from the RO operation through a Request For Information (RFI) dated February 28, 2017 (2017-02-28 Email RML 369-06 Request for Information – SJC). A copy of the RFI is attached for reference. The licensee provided a response on March 6, 2017 (2017-03-06 Email SWM RML 369-06 Response to RFI – SJC) that included an updated Decommissioning Plan for Termination of Radioactive Materials License CO-396-06. Section 7.7 of Appendix A of the Decommissioning Plan discusses the characterization and disposal of the cartridge filters and RO membranes. A copy of the Response to RFI is attached for reference. CDPHE subsequently approved the plan through Condition 15.B of the issued RML CO-396-06. A copy of the license that has since been transferred to CLL is attached for reference.
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