2019-01-03_REVISION - M1977300 (2)

Home Browse Search

�' COLORADO LEGACY LAND fluctuation in the pumping performance will give the operator a wide range of versatility.By maximizing the water level depth,the active water treatment system can be shut down to promote in-situ treatment.At this point the system will only be monitored remotely until the operator is required to continue active treatment. The General time frame is anticipated to be 6-month operation and 6-month offline. With the goal to maintain the lowest level of the mine pool as achievable. 7.The Operator is proposing to remove several total and dissolved metals from the groundwater sample suite, all of which are contained within Tables 1 through 4 of"The Basic Standards for Ground Water"(Regulation No. 41).The Division is an implementing agency,responsible for implementing Water Quality Control Commissions'(WQCC)standards and classifications for discharges through its own regulatory programs after consultation with the WQCC and the Water Quality Control Division.Therefore,the Operator must make a demonstration that the analytes proposed for removal are not currently exceeding the Table Value Standards in Tables 1-4.Any analytes which exceed the Table Value Standards,must remain in the groundwater sample suite.If a particular analyte is not exceeding the Table Value Standard,then this analyte could potentially be removed from the groundwater sample suite.In accordance with Rule 3.1.7(8),an Operator shall demonstrate to the satisfaction of the Division,that reclamation has been achieved so that existing and reasonable potential future uses of groundwater are protected.Therefore,any analytes which meet the criteria for removal will need to be added back into the groundwater sample suite prior to release of the Reclamation Permit,as part of the Operator's demonstration under Rule 3.1.7(8). Response: Table 1 of Technical Revision 27 has been revised to include CDPHE groundwater criteria(Regulation No. 41)and surface water criteria(Regulation No.38). Analytes which exceed one of the two criteria are retained for quarterly analysis. Analytes that do not exceed either criteria are recommended for removal. 8. The Operator has indicated monitoring wells MW-4 and MW-5 were removed in 2008.Please explain why these monitoring wells were removed.In addition,provide documentation which demonstrates the removed wells were abandoned in accordance with the requirements of the Division of Water Resources. Finally,a review of the Environmental Protection Plan approved in 2012 and revised in 2016,lists MW-4 as an existing well. Please clarify this discrepancy. Response: "The Environmental Protection Plan,Revision 1"(Wheatstone 2016)states that MW-4 and MW-5 were removed in 2008 during reclamation activities,this report does not provide additional details or documentation regarding the removal. Figure 2-2 of the"The Environmental Protection Plan,Revision 1"(Wheatstone 2016)shows both MW-4 and MW-5 as removed wells. Since all of the monitoring wells at Schwartzwalder are sequentially numbered Technical Revision 27 list MW-4 and MW-5 as removed so that reviewers may see a complete list of monitoring wells. 9. The Division conducted a review of the various permit revisions which authorized new groundwater sampling locations and discovered that several of the reported Sample IDs do not match the Sample IDs which were provided to the Division in the permit revisions.Please review the following table and specify which of the currently reported Sample ID's are associated with the Sample IDs listed below: Sample IDs Not Reported Associated Permit Revision Notes L1 TR19 Replaced MW-10 L2 TR19 Replaced MW-11 L3 TR19 L4 TR19 L5 TR19 L6 TR19 L7 TR19 Mine Refill EPP Response: PAGE 4 OF 16