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2021-05-12_REVISION - M2012032 (2)
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2021-05-12_REVISION - M2012032 (2)
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Last modified
1/10/2025 6:12:06 AM
Creation date
5/17/2021 6:11:56 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M2012032
IBM Index Class Name
REVISION
Doc Date
5/12/2021
Doc Name
Adequacy Review Response
From
Ouray Silver Mines, Inc.
To
DRMS
Type & Sequence
TR12
Email Name
LJW
THM
Media Type
D
Archive
No
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Ltn�ar 5►Lv�Nhnr�s <br /> • Pond 3 is a lined facility whose discharge is monitored at Outfall 002A and regulated by <br /> the Colorado Department of Public Health and Environment. OSMI proposes that no <br /> replacement well be drilled. <br /> 4. The goal for GW-4 required by TR-10 was to facilitate the monitoring of the passive water <br /> treatment system specifically for impacts to water quality. Given that pond 3 is lined and now a <br /> surface discharging facility, GW-4 would serve as a leak detection system, an Environmental <br /> Protection Facility(EPF). What would be the proposed replacement EPF to ensure that pond 3 <br /> is functioning correctly if GW-4 is to be abandoned? <br /> For the reasons presented in the Item 4 response, OSMI proposes Pond 3 is best monitored by the <br /> existing requirements under permit CO0000003. <br /> 5. The proposed location of GW-4R is distant and down gradient from pond 3 than GW-4 thus it <br /> would not isolate the water quality impacts from the passive treatment system alone. Therefore, <br /> it is inferred that GW-4R would be a generic groundwater monitoring well for the entire <br /> Revenue Mine site. Please provide the justification as to why GW-4R is being proposed to <br /> replace GW-4, despite being a well with a seemingly different purpose. <br /> The original revision request map placed the proposed GW-4R in an erroneous location. For the <br /> reasons previously discussed, OSMI no longer proposes a replacement well for GW-4. <br /> 6. The proposed GW-4R is a replacement EPF. Pursuant to Rule 6.4.21(7) Prior to approval the <br /> Division will require the proposed well construction schematics, well location, drilling methods, <br /> cuttings handling and circulation water handling. <br /> As discussed in the responses to items 3, 4, and 5, OSMI no longer proposes a replacement well <br /> G W-4R. <br /> 7. Contours on Map I suggest that the proposed GW-4R will be located at approximately the <br /> same elevation as GW-4 but will by twice the depth. Please provide justification of the <br /> construction details of the proposed GW-4R. The justification should address but is not limited to <br /> the reasoning for the increased depth,purpose behind the use of a packer/bentonite plug and the <br /> estimated depth to groundwater contact. <br /> As discussed in the responses to items 3, 4, 5, and 6 OSMI no longer proposes a replacement <br /> well GW-4R. <br /> 3 1 P a g e <br />
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