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<br />however, we also need an accurate measure of the percent <br />of sulfide present in each ore type. <br />d. The method proposed for disposal of spent ore seems <br />plausible. However, there appears to be potential for <br />degradation of surface end groundwater. The ore analysis <br />presented suggests the presence of arsenic in high <br />concentrations. Accordingly, the operator should <br />demonstrate methods to be used, such as a clay cap, to <br />minimize air and water movement into the respread spent <br />ore during final reclamation. Surface water diversions <br />may also be helpful, especially where spent ore is <br />exposed above ground. Additionally, some type of <br />appropriate impermeable liner may need to be employed <br />within the disposal areas to prevent possible toxic <br />constituents from leaching into groundwater resources. <br />e. Use of water from Little Deadwood Gulch for process <br />water should be evaluated and approved by a qualified <br />representative of the State Bngineer's Office. The <br />operator may be required by the SBO to demonstrate <br />adequate water rights for this particular operation. <br />f. The operator has proposed a zero discharge facility. <br />It should be noted that any discharge of excess process <br />water back to Little Deadwood Gulch will require an NPDBS <br />water discharge permit by the Colorado Department of <br />Health, Water Quality Control Division. <br />g. The operator has proposed a disposal method for processed <br />ore (filter cake) to be placed in the open cuts and mine <br />openings of the disturbed area while at a moisture <br />content of approximately 25 percent. Thus, seepage of <br />moisture from the filter cake into the surrounding strata <br />will constitute a discharge to groundwater. Therefore, <br />the operator should state what measures will be taken to <br />comply with the provisions of Rule 3.1.7 for protection <br />of groundwater. <br />10. SPILL CONTAINMBNT <br />The Division appreciates the information provided in the <br />response providing estimated quantities of industrial <br />chemicals used in the operation. However, from a bond <br />calculation perspective, it is difficult to determine from the <br />information provided what the probable maximum quantity of <br />potentially hazardous materials will likely be on site at any <br />one point in time during each phase that would need to be <br />removed from the site and properly disposed of by an <br />independent contractor hired by the Division in the event of <br />bond forfeiture. Removal of industrial chemicals from a mine <br />site is a necessary component of final reclamation. From e <br />10 <br />