2021-09-27_REVISION - M1990057

• Permit No: M1990057
• IBM Index Class Name: REVISION
• Doc Date: 9/27/2021
• Doc Name: Adequacy Review Response
• From: The Union Milling Contractors
• To: DRMS
• Type & Sequence: CN1
• Email Name: DMC
• Media Type: D
• Archive: No

Mr. Dustin Czapla 5
CDRMS
September 24, 2021
Response
Structural agreements can be found in Appendix 19-1 Through Appendix 19-6. CJK received
one signed agreement back from Xcel Energy. A copy of the Engineering report can be found
attached (Appendix 19-8). These documents are attached for your reference.
12. Rule 6.4.21 EXHIBIT U — Environmental Protection Plan - Designated
Chemical(s) and Material(s) Handling
Pursuant to Rule 6.4.21 (6)(a) please fully describe the procedures for the disposal,
decommissioning, detoxification or stabilization for all designated chemicals and
toxic or acid-forming materials. Specifically describe measures to be taken to
prevent any unauthorized release of pollutants to the environment. Include
adequate reclamation and closure practices for such designated chemicals, toxic
or acid-forming materials and how unauthorized discharge of acid mine drainage
will be prevented.
Also, pursuant to Rule 6.4.21 (6)(b) please submit a narrative description or plan
that:
(i) describes how all designated chemicals used in the extractive metallurgical
process will be handled during active mining operations, during periods of
Temporary Cessation, and disposed or detoxified at the conclusion of
operations so as to comply with all applicable environmental protection and
reclamation standards and regulations;
Response
CJK will implement the procedures outlined in:
• Section 21.0 Rule 6.4.21 Exhibit U - Designated Mining Operation
• Section 21.5 Process Chemicals, Evaluation Designation
• Section 21.6 Designated Chemicals and Material Handling
• Applicable MSHA and OSHA health and safety regulations and the guidelines
summarized the Material Safety Data Sheets
In addition, chemical inventories, chemical acquisition and disposal management, and security
protocols will be included in Facility Best Management Operating Procedures.
(ii) describes how materials that have the potential to produce acid mine
drainage or are toxic or acid-forming will be handled to ensure that the
affected lands will be reclaimed and returned to the approved post-mining
land use; and
Response
Currently the ore sources are producing acid mining drainage from historical mine dumps
created in the late 1800 and early 1900's. CJK will be removing, processing the acid generating
ore such that the material will be in an alkaline, metal stabilizing state that will mitigate the
production of acid mine drainage. In addition, the TSF is designed as a "no-discharge" facility.
The post milling land use is summarized in section 5. Rule 6.4.5 Exhibit E - Reclamation Plan.