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COLORADO <br /> Division of Reclamation, <br /> Mining and Safety <br /> Department of Natural Resources <br /> Mr. Graham Roberts <br /> Environmental Supervisor <br /> Trapper Mine, Inc. <br /> P.O. Box 187 <br /> Craig, Colorado 81626 <br /> 3 April 2023 <br /> Re: Trapper Mine Inc; Permit C1981010 <br /> DRMS Adequacy Review GW Addendum Permit Revision PR11 <br /> Dear Mr.Roberts: <br /> On March 30, 2023 the Division sentyou a copy of the Interoffice Memorandum regarding the <br /> Groundwater Review(2) dated March 29, 2023 from Leigh Simmons with DRMS. Upon further <br /> consideration and discussion with Mr. Simmons, the Division is submitting amended adequacy <br /> questions pertaining to Rules 2.05.6(3) and 4.05 in relation to items from the March 29, 2023 <br /> memo numbered 15 and 16. Also additional items must be addressed. <br /> 15. Proposed Section 4.8.5.2 (page 4-242) describes the groundwater monitoring plan. The text <br /> states that: <br /> In Technical Revision TR-93, the Division and Trapper Mining Inc. agreed that well GP- <br /> 9 is the point of compliance for the Basic Standard for Ground Waterfor the Third <br /> White sandstone. In Technical Revision TR-96, the Division and Trapper Mining Inc. <br /> agreed that the Coy well is the point of compliance for the Basic Standards for Ground <br /> Water for the Flume Gulch alluvium. <br /> GP-9 is not appropriately located to act as a point of compliance for the disturbance proposed <br /> with PR-11. <br /> Please propose additional points of compliance for all aquifers that have the potential <br /> to be impacted by the disturbance proposed with PR-11, including alluvial aquifers. <br /> Trapper response: "Wells CY-1 and CY-2 adequately monitor the 1st and 2nd White <br /> Sandstone aquifers downgradient of the present I Pit mining, while well CY-A monitors <br /> downgradient of the Coyote alluvial aquifer. Well CY-3 will adequately monitor the 3rd <br /> White Sandstone downgradient of the J Pit mining. Before Points of Compliance and <br /> associated standards are set, we feel these wells should just be considered downgradient <br /> monitoring wells until such time as sufficient data is available to define natural background <br /> concentrations. This issue will be further evaluated in a forthcoming Technical Revision to <br /> address a new I Pit mine plan. <br /> 1 <br />