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2019-05-09_INSPECTION - M1977300
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2019-05-09_INSPECTION - M1977300
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Last modified
1/5/2025 5:18:54 AM
Creation date
5/9/2019 1:31:04 PM
Metadata
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Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
INSPECTION
Doc Date
5/9/2019
Doc Name
Inspection Problem Corrective Action
From
Colorado Legacy Land
To
DRMS
Email Name
MAC
Media Type
D
Archive
No
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COLORADO LEGACY LAND <br /> During the first quarter 2019 sampling event, a sample was collected from the SW-NWRP water quality <br /> monitoring station,which is near the cut-off wall,downgradient of the red and green pool locations.The total <br /> uranium concentration was 0.0156 mg/L(Sample Date: 2/26/19),which is below the USEPA MCL. <br /> If it is assumed the water from the SW-RED-POOL and SW-GREEN-POOL sample locations are representative <br /> of sequential seeps from the NWRP,then the water is naturally attenuating prior to mixing with Ralston Creek. <br /> The hypothesized flow path begins with water in the ephemeral drainage above of the NWRP,then expresses <br /> as surface water in the green algae pool(Sample ID:SW-GREEN-POOL),then begins to mix with Ralston Creek <br /> (Sample ID: SW-RED-POOL),and finally joins Ralston Creek(Sample ID: SW-NWRP) prior to entering the by- <br /> pass pipeline. <br /> The downgradient sample location SW-BPL is below the USEPA MCL, indicating that contaminated surface <br /> waters are not leaving the affected lands. Additionally,an alluvial capture system is used in place consistent <br /> with the Environmental Protection Plan to prevent potentially contaminated groundwater from leaving the <br /> site. The water from the sumps is pumped back onsite for treatment. <br /> Correction Action#2-Hydrologic Balance: <br /> By the corrective action date,the operator shall submit a detailed construction schedule for installation of the <br /> surface water control structures approved in Technical Revision-23 for the waste rock piles. Any proposed <br /> revisions to the approved plan must include a detailed construction schedule and be submitted in the form of <br /> a Technical Revision or Amendment application by the corrective action date with the appropriate fee. <br /> Response: <br /> A revised design and detailed schedule for the installation of the surface water control structure at the North <br /> Waste Rock Pile is provided under separate cover in Technical Revision#28 to Mine Land Reclamation Permit <br /> M-1977-300. <br /> Observations: <br /> In response to the observations submitted in the inspection letter dated April 9,2019,Colorado Legacy Land, <br /> LLC would like to provide the following corrections: <br /> • On page 1,Cliff Yeckes is not an operator representative and should be removed from this designation. <br /> Mr.Yeckes works with McGriff,Seibels&Williams who is CLL's insurance/surety broker. <br /> • On page 2, the sentence "....(which operates approximately 6 months during the year)" should be <br /> revised to more accurately read,"...(which operates periodically throughout the year)". <br /> • On page 2, the sentence "The new 50 HP submersible pump" should be revised to more accurately <br /> read, "The new 60 HP submersible pump". As discussed with DRMS,the submersible pump size was <br /> incorrectly referenced in TR 27. The corrected as-built is provided under separate cover to DRMS. <br /> • On page 2, the sentence "Since that time, the operator has continued to demolish and remove <br /> structures from the site, including the old water treatment plant" should be more accurately read, <br /> "Since that time,the operator has successfully relocated water treatment plant operations to the mesa, <br /> demolished structures in the valley, placed demolition debris underground in accordance with the <br /> Mine Land Reclamation Permit,and begun alluvial excavation activities." <br /> PAGE 2 OF 2 <br />
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