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~~r <br />Oswald, Bob <br />From: Oswald, Bob ,/ RECEt'~/E® <br />Sent: Thursday, December 22, 2005 10:21 AM <br />To: 'marnie medina@blm.gov'~ ~ Z ~`~ <br />Cc: Posey, Harry; Humphries, Bruce <br />Subject: Proposed GW monitoring below Golden Wonder Mine ~ <br />.r _._..~_ BhieiwofMinerahend0eota0y <br />Mamie - In response to your questions about a future groundwater monitoring well program, to be performed in advance of <br />Lance Barker's expansion of the Golden Wonder Mine operation, here is some information and some thoughts from our <br />office. <br />Our Hard Rock Rules &Regs describe our GW jurisdiction and the operator's need to monitor. These are available from <br />the DMG website: vdww.mining.state.co.us. Click on Rules and Regs (in the column on left), then click on Hard Rock <br />Rules for the .pdf document. Scroll down to Rule 3.1.7 in the table of contents in the first few pages, to locate the rule that <br />discusses groundwater monitoring. <br />As far as this office is concerned, Lance may implement his proposed monitoring well program, under an approval from <br />your BLM office, on lands not yet part of the Golden Wonder Mine permit. The monitoring program could be performed <br />outside the permit area because it would not be considered mining or prospecting, and therefore it would not be bonded in <br />the short-term. Longer term, however, this office would want the well areas to be included within an expansion of the <br />existing Golden Wonder permit, or under a new permit. <br />A precaution here: this office cannot provide input from a meaningful review of a proposed program if it is not part of the <br />permit. If a monitoring well program is developed and implemented, prior to the area to be affected by the program being <br />included into the permit, the operator runs the risk of the program not being accepted by DMG. In other words, even <br />though he may be approved by your office for a monitoring program (well locations, sampling parameters, etc.) when the <br />program is eventually included in the DMG permit and it comes under ourjurisdiction, our review may find it insufficient. If <br />that is the case the operator will have to start over to correct those deficiencies. <br />Our advice for proceeding on the safest course (intended for the operator) is to prepare and submit to DMG an <br />amendment to the existing permit, that will include the areas to be affected by the monitoring well program and the <br />eventual mining activity. This process allows for our review and comment, which will ensure that the program will meet our <br />standards. This may be carried out with coordination between our two agencies to ensure compliance with both sets of <br />requirements. If you are in contact with the operator, you might pass this along. I have not been contacted by Lance, but <br />will also try to inform him of these thoughts before he gets too far along. <br />AttachE:d are a few pertinent documents from the permit file, in this order: <br />1.10/13/04 DMG inspection at the Golden Wonder mine. Paragraph 1 references the off-permit visit of the lower adit site. <br />2. Photos from the 10/13/04 visit to the lower adit site. <br />3. 12/21/04 DMG cover letter to GW memo, for lower adit site. <br />4. 12/20/04 GW memo to operator. <br />(These are .tif files, which I hope that you can open on your computer.) <br />Lance has already taken water samples for several quarters at a few locations in the vicinity of the lower adit, though they <br />were nut from GW monitoring wells. You might ask him for copies of the analyses from those. <br />If you (or Lance) have questions, please contact me. Have a great holiday -Bob <br />~~ <br />M1970000.TIF M1970001.TIF M1970002.TIF <br />M1970003.TIF <br />