REV08910

• Permit No: M1979094HR
• IBM Index Class Name: Revision
• Doc Date: 7/1/1996
• Doc Name: REVIEW OF TR APPLICATION C-JD-7 MINE PN M-79-094
• From: DMG
• To: LARRY OEHLER
• Type & Sequence: TR3
• Media Type: D
• Archive: No

• III IIIIIIIIIIIIII
999/ ~1 II •
,I'E OF
COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of N, lura Resources
1 J I } Sherman SL. Room ? 15 ry

Denver, Gllnnidu H0203 ~
~~

Phone: [phone]JSG7 II
FAX: 13031 B12-H 106
DEPARTMENT OF
NATURAL
Date: July 1, 1996
RESOURCES
To: Larry Oehler Ro Romer
Y
Governor
From: James Dillie
lames s. EDenneaa
E~eculive Director
Re: Review of Technical Revision Application
Michael B. Long
C-JD-7 Mine, Permit No. M-79-094 Division Director
At your request, I reviewed the geotechnical aspects of the TR application and have the following
comments/reconunenda[ions:
Cotter states that "the disposal cells are well above the present ground water table" but did not
provide any information regarding the depth to groundwater. I suggest you request the depth to
groundwater information and, in order to evaluate potential impacts to groundwater, I suggest you
request a lithologic log of the strata below the holding cells.
Cotter proposes to construct runoff control berms to divert surface water away from the disposal
cells. However, the map that was submitted only shows the cover slot berms. Where will the
diversion berms be located?
Cotter did not provide any information about the size and shape of the diversion ditches or the
holding pond. As you are aware, stormwater structures must be constructed to contain the 10-year,
24-hour even[.
4. Importation of backfill material, or in this case disposal of low grade ore material, is regulated by
Rule 3.1.5(9). This Rule speaks of inert structural fill generated outside of the approved permit area.
It is currently not clear whether the Whitewater material is inert or not. Inert material is defined
(Rule 1.1(24)) as any non-watersoluable and non-putrescible solid unless such material is acid- or
toxic-producing. The salt wash formation is not a sulphide deposit, so it is not considered an acid-
producing material. However, the salt wash formation does contain uranium and vanadium, as well
as other heavy metals, so it has the potential to produce toxic material into the environment. As
defined in Rule I.I(1), toxic-producing materials contain detrimental amounts of chemical constituents
(metallic compounds). Detrimental amounts of chemical constituents, as defined in Rule 7.2.6(1), are
quantities sufficient to adversely affect human health, property or the environment.
The Division has yet to define the amount of uranium that would be considered detrimental to human
health, etc., so it is possible that the importation of the Whitewater material could qualify the site as a
DMO. In addition, the material may not quality as inert and would, therefore need Board approval to
place it at the JD-7 site. Maybe we should discuss with Bruce.
In my opinion, except for the diversion berms, the holding cells are adequately designed to minimize
impacts to the environment. The cover of 3+ feet should sufficiently reduce exposure potential to radio-
active elements. In addition, by diverting runoff and establishing a vegetative cover, erosion problems
should be minimal.
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