INSPEC25586

• Permit No: M1986076
• IBM Index Class Name: Inspection
• Doc Date: 8/19/2002
• Doc Name: Response to Corrective Actions
• From: DMG
• To: James Bender
• Inspection Date: 7/19/2002
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman SL, Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
DIVISION OF
p`' Y
dl~~~ ~~ MIN&RALS
GEOLOGY
~~ RECLAMATION
MINING•SAFETY
Angust la, 2002 / CF/~~~
/ AEG Bill Owens
James Bender 1/ 9 Governor
5529 US Hwy. 64 ~r~~+0° °t Mf ' ~~ Executive D rector
Fam7ngton,NM 87401 °E`~'=..utg Ronald w. wnany
°pf0by'Acting Division Director
Re: Incas Mine, Permit M-1986-076, Response to Corrective Actions, Inspection of my 19, 2002.
Deaz Mr. Bender,
Thank you for the response letter dated August 10, 2002; in which you discuss the activities performed toward
correcting the problems noted in my last inspection report. Your submittal has corrected the problem as it was
noted in the report. I will try to cover all the additional topics in your letter and answer the questions you raise, in
the following paragraphs.
Water Oualit~pling
We have noted the different lab (named on the chain-of-custody form) you aze dealing with for the surface water
sample analysis. This new lab, Inter Mountain Labs of Farmington, will be fine to use as long as they can perform
the analyses as required. This means that all the required tests of the complete suite can continue to be performed,
and that they are performed down to a sufficiently low detection level. ff you or they have questions about that,
please refer to the details shown on the prior analyses (from your files).
We have not heard from Bob Hill since his last annual report submittal on December 31, 2001. It is good you were
able to retrieve the records and discuss this permitted DMO operation with him; I believe that this will help make
the transition less problematic for everyone. Please try to ensure that he has forwarded all permit-related records to
you.
You stated that the water samples for 2000 and 2001 were taken, but that they were never analyzed. This is
unfortunate since one of the main parameters to monitor and regulate is cyanide, but cyanide quickly degrades in a
sample. It is known that the site was active during 2000 and 2001, making the event of a cyanide release a
possibility. Cyanide is regulated, and it is incumbent on a DMO operator to show that such releases did not occur.
There are no data in the record to show that a cyanide release did not occur, and now there is no chance to obtain
the missing information to fill the gap in the record. I will be discussing this item with my supervisor and will
inform you if further discussion or enforcement action is indicated.
Regarding your offer to retrieve the 2000 and 2001 samples from Bob Hill and have them analyzed, I have
discussed this question with our staff in Denver. We believe that getting the samples analyzed is still a worthwhile
endeavor, but there is a question as to whether any pazameters will still yield valid results after all this time in
storage. It is presumed that the samples are no longer "fresh" after being kept in storage for one to two yeazs, and
being subject to the variations inherent in outside ambient temperatures.
Required analysis of the samples is to include conductivity, cyanide, pH, sulfates, and total dissolved solids. We
can safely say at this time that all five parameters have potentially been affected by the long period of storage,
though perhaps in predictable ways, making it possible to infer certain limited conclusions from the results. It is