1997-04-02_HYDROLOGY - M1984049

• Permit No: M1984049
• IBM Index Class Name: Hydrology
• Doc Date: 4/2/1997
• Doc Name: REVIEW SITE FILES PURSUANT TO YOUR LETTER OF 02/19/97 IN RE HOWARDSVILLE MILL PN M-84-049
• From: DMG
• To: WALLY ERICKSON
• Media Type: D
• Archive: No

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STATE OF COLOMDO
DIVISION MINERALS AND GEOLOGY
DeparlmeN of of Natural Resources
1311 Sherman St, Room 215 I{�
Denver,Colorado 80203 I
Phone [phone]
FAX [phone]
DEPARTMENT OF
NATURAL
RESOURCE
Roy Romer
DATE: April 2, 1997 Governor
lames 5 Lochhead
hec.ive Duecmi
TO: Wally Erickson Michael a Long
Division Director
FROM: s--Harry Poscyr/xom��
RE: Review: Site files pursuant to your letter of February 19, 1997 in re:
Howardsville Mill, Permit No. M-84-049
Your adequacy response letter regarding the EPP for Howardsville Mill appears to cover all
of the issues that I have considered regarding acid and toxic materials handling, groundwater
monitoring, and acid rock drainage potential. This memo confirms that I have studied the
operators submittals and your response. As I understand the situation, there may be still some
confusion among the parties about and potential parties about the permit responsibilities, and
you will address these in part at the April board hearing. if I can be of assistance, let me
know. I will not be in town on the 23rd of April or the morning of the 24th.
Yesterday we discussed a proposal submitted by the court-appointed receiver to revise the
monitoring schedule and the analytical parameters list. As indicated, the operator is not
required to monitor molybdenum, although it maybe useful to do so as Mo is a known
toxicant. All other metals should be quantified in the ground and surface water monitoring
and at the maximum detection levels identified in your letter.
Regarding the court-appointed receiver's request to remove several of the groundwater
monitoring points, the operator is obligated already to monitor most of the points identified
by the Division in your correspondence, and the remaining wells were specifically identified
as local points of groundwater contamination. Therefore, I see no compelling reason to
remove any of the groundwater monitoring requirements.
The court-appointed receiver has requested also that the frequency of monitoring be lowered.
As you know, even though the Division recommended monthly monitoring, the Rules and
Regulations require only five quarters of baseline monitoring. It could work to the Operator's
advantage to monitor groundwater as frequently as possible during the baseline monitoring
phase, because the Division will accept as ambient conditions the highest values observed
within any quarter of sampling. Certainly, a greater monitoring frequency represents some
expense, but if the Operator chooses to collect samples only quarterly, the Division cannot
compel them to do otherwise.