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2022-05-13_REVISION - M1977300
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2022-05-13_REVISION - M1977300
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Last modified
5/16/2022 8:45:14 PM
Creation date
5/16/2022 8:56:16 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
Revision
Doc Date
5/13/2022
Doc Name
Adequacy Review Response #2
From
Colorado Legacy Land
To
DRMS
Type & Sequence
AM6
Email Name
AME
MAC
Media Type
D
Archive
No
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COLORADO LEGACY LAND <br /> quarterly sampling over a 10 year period,which would include a total of 520 sampling events (not <br /> 260)for 13 monitoring locations.Given the operator's proposed plan to remove the bypass <br /> pipeline and re-establish creek flows across the mine site,it is especially important the Division <br /> continues to hold costs for sampling all surface water monitoring locations at the required <br /> quarterly frequency over the full 10 year period.Please adjust these costs accordingly. <br /> b. In its adequacy item#36(b),the Division required the operator to adjust the Groundwater b. Revised as requested. <br /> Monitoring costs to cover quarterly sampling over a full 10-year period.In its response,the <br /> operator stated"revised as requested".However,the revised cost for this item does not cover <br /> quarterly sampling over a 10 year period,which would include a total of 560 sampling events(not <br /> 280)for 14 monitoring locations(12 wells with water quality sampling+2 spigots).Please adjust <br /> these costs accordingly. <br /> Exhibit U-Designated Mining Operation Environmental Protection Plan(Rule 6.4.21): <br /> 22 Under Section 7 of the revised EPP,please add a description of the bulkheads installed in the Steve and Revised as requested. The text in Exhibit U has been updated to include a description of the bulk heads and CLL has included a <br /> Pierce adits,which are considered Environmental Protection Facilities.If CLL has access to the as-built copy of the As-Built Report provided in Technical Revision#9 with this submittal. <br /> drawin s for these bulkheads,please provide copies of these drawings. <br /> Exhibit U-Designated Mining Operation Environmental Protection Plan(Rule 6.4.21): <br /> 23 Under Section 7,Table 7-1 provides a list of reclamation activities completed and in progress.The two These two areas are in the alluvial valley and are currently being reclaimed as part of the excavation project. The remaining <br /> items from this list shown to be"in progress"are the Fill Material Borrow Area and Ore Sorter Area reclamation activities in these areas include excavation of contaminated soils,regrading,replanting/reseeding in accordance <br /> Decommissioning.Please describe where these areas are located within the permit area and what with Exhibit E. <br /> reclamation activities remain in these areas. <br /> Exhibit U-Designated Mining Operation Environmental Protection Plan(Rule 6.4.21): <br /> 24 Under Section 7.1,the operator provides a list of four chemicals used in the water treatment process. Revised as requested. <br /> Please provide the maximum volume of each of these chemicals that is stored in the plant at any time. <br /> Exhibit U-Designated Mining Operation Environmental Protection Plan(Rule 6.4.21): <br /> Under Section 7.1,the operator states"the plant floor was constructed with an 8-inch high berm to serve as Revised as requested. The text has been updated to state that plant can contain up to 110%of the maximum storage capacity <br /> secondary containment for all the structures in the building".Please provide additional details on the including hazardous chemicals. <br /> secondary containment system installed inside the plant,including whether it was designed to contain at <br /> least 110 percent of the maximum storage capacity of all primary containers holding hazardous chemicals. The containment inside the water treatment plant is capable of holding approximately 10,000 gallons.Primary containers inside <br /> the Water Treatment Plant include: IX Vessels,anti-scale tank,chemical tote-pH adjustment,chemical totes-Stock <br /> consumables. <br /> IX Vessels: <br /> 3 IX vessels are connected in series and each one can be isolated as required.2 vessels are used in normal operation.Each <br /> 25 vessel will contain resin and treated water.Each vessel will contain 50%resin and 50%water. <br /> IX-1 =1,000 gallons <br /> IX-2=1,000 gallons <br /> IX-3 =1,000 gallons <br /> Anti-scale Tank: <br /> 1 Tank used to supply anti-scale additive=900 gallons <br /> pH Adjustment-Standard Chemical Tote: <br /> 1 tote= 275 gallons <br /> Stock reagents-Standard Chemical totes: <br /> Va inquantities with a maximum of 10 totes <br /> PAGE 9 OF 12 <br />
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