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RESPONSE TO COMMENT MATRIX <br />PAGE 1 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 1 During a meeting between the Division and Colorado Legacy Land, LLC held on May 24, 2018, the Division was informed that several of the items which have been approved for disposal in the Minnesota Adit contain asbestos. Asbestos is designated as a hazardous substance with a reportable quantity in the Superfund regulations. Please identify the State and/or Federal reporting limits for asbestos. The demolition and disposal of asbestos containing materials are regulated by the Air Pollution Control Division (APCD) of the Colorado Department of Public Health and Environment. Please specify if the APCD was consulted regarding the disposal of asbestos containing materials at the mine site. <br />Our total quantity (32 LF and 45 SF) is less than the reportable quantity limits as defined by both the US EPA and the State of Colorado shown below, respectively - https://www.epa.gov/sites/production/files/documents/nps5da.pdf <br />• 260 LF <br />• 160 SF <br />• 55 gallon drum https://www.colorado.gov/pacific/sites/default/files/AP_ASB_Abatment-Permit-Application-Form.pdf <br />• 260 LF <br />• 160 SF <br />• 35 ft3 Engineering Analytics (EA) was contracted to perform the asbestos inspection and to assist with the permitting as their scientists and technicians assigned to the project have the proper certifications from the CDPHE APCD. APCD regulations were applied to the materials/buildings that were inspected for demolition. Once the abatement (asbestos removal) is complete, and prior to demolition, CLL will apply for a demolition permit which is required to be submitted to the APCD. This is the notification mechanism to APCD. No other consultation with APCD is required 2 The Operator is proposing to include solid waste generated from the water treatment process in the inventory of items to be disposed of in the Minnesota Adit. Table 1 contains a list of the materials to be included in the inventory list and contains the associated Uranium and Radium-226 levels. Please specify which analyses were performed on the cartridge filters and RO membranes and provide the Division with a copy of the results from the laboratory which conducted the analyses, if applicable. <br />The samples were analyzed by the internal lab using test methods based on SW-846 Test Method 6020B test for Uranium and EPA 903.0 to test for Radium-226. Copies of the analytical lab results are attached. <br />3 The chemical analyses of the cartridge filters and RO membranes occurred in 2016. Please confirm the For clarification, all cartridge filters and RO membranes requested for disposal are from the New Water Treatment Plant (NWTP) and are representative of the concentrations that