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2022-09-06_REVISION - M1977300
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2022-09-06_REVISION - M1977300
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Entry Properties
Last modified
1/20/2025 7:27:38 AM
Creation date
9/6/2022 10:12:01 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1977300
IBM Index Class Name
Revision
Doc Date
9/6/2022
Doc Name Note
4th Adequacy Reponse
Doc Name
Adequacy Review Response
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 /> $CHWARTZWALDER MINE <br /> time period does not fit with historical data and there is no plausible explanation that CLL knows other than <br /> this mislabeling and poor nomenclature to explain this variability during this time.Regardless,the few months <br /> of variable data in 2017 do not alter the conclusion that the mine pool has been chemically stable for the last <br /> four years. <br /> E.5.2.3. Chemical Stabilization of the Mine Pool Discussion <br /> The concentrations and linear regressions for uranium and molybdenum over the last 3.5 consecutive years <br /> are shown on Figure E-8. The uranium concentrations (dissolved and total) have maintained an average of <br /> approximately 12 mg/L since March 2018 with a positive slope. The majority of the uranium concentrations <br /> are in the 10 to 15 mg/L range with more recent data at approximately 20 mg/L. The molybdenum <br /> concentrations(dissolved and total) have maintained an average of approximately 0.6 mg/L since March 2018 <br /> with a slight negative slope. These stable average concentrations indicates that the in-situ treatments have <br /> been effective in controlling the concentrations of these two metals that are particularly elevated in <br /> concentration in this mine pool environment. The January 2020 in-situ treatment did not show the dramatic <br /> decreases in dissolved uranium concentrations as during the first two in-situ treatments, which is likely an <br /> indication that an environment favorable to U(IV)has been achieved. <br /> A figure that combines multiple parameters(dissolved)with the mine pool elevation,in-situ treatment periods, <br /> and when the RO reject was injected back into the mine is presented on Figure E-9. Note that RO reject was <br /> injected back into the mine on a continuous basis starting in mid-2017 and the two events before that, e.g., <br /> 2013 and 2015,were only temporary periods of injection.Also note that the dates for the mine pool elevation <br /> correspond to the sampling dates and CLL does not have mine pool elevation data before December 2016. <br /> There does not appear to be any correlation between the mine pool elevation and the parameter concentrations <br /> shown on Figure E-9.The observations from Figure E-9 follows: <br /> • The uranium and molybdenum concentrations are directly affected by the in-situ treatments, e.g., <br /> decrease during treatment and generally staying low for several quarters,with a subsequent increase <br /> toward baseline conditions. <br /> • The arsenic and iron concentrations follow a similar pattern as the uranium and molybdenum <br /> concentrations. The arsenic and iron concentrations also increase in the 2017 period of the suspect <br /> data and coincide with a time that some of the RO concentrate was returned into the mine pool through <br /> the "open hole". The increase in concentrations appears to have occurred during the time where the <br /> continuous injection of RO concentrate began and is interpreted to be a result of leaching from broken <br /> rock in the open hole. Other than during that period (2016-2017) arsenic and iron concentrations <br /> decrease as a result of in situ treatment and have remained in line with concentrations observed after <br /> the refilling and pre-dewatering period. Iron is typically insoluble in oxidized and neutral conditions <br /> observed when the mine initially filled and transitioned to slightly soluble conditions when the mine <br /> became mildly reducing from being filled and sealed and the introduction of in-situ treatments. This <br /> should be considered a positive development that is consistent with a lack of increase in sulfate as not <br /> iron increasing due to iron sulfide oxidation, but rather from reductive solubility increase. Arsenic <br /> concentrations generally follow this same trend—low solubility in oxidized conditions with iron <br /> present,and slightly more soluble in mildly reducing conditions.However,a change from 3.6 ppb mean <br /> AUGUST2022 26 AMENDMENT <br />
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