GENERAL41512

• Permit No: M1977310
• IBM Index Class Name: General Documents
• Doc Date: 7/3/2007
• Doc Name: Review of Supplemental Data
• From: DRMS
• To: DRMS
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
7373 Sherman St., Room 275
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
June 27, 2007
V
To: David Bird /Kate Aickford
From: G. Russell Means
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COLORADO
DIVISION OF
RECLAMATION
MINING
SAFETY
Bill Owens
Governor
Russell George
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
Subject: Review of Cotter supplemental data for Uranium Designated Mining Operation Appeals.
David and Kate:
Please find enclosed Cotter Corporation's timely submitted additional information to supplement the
data provided to the Division in regards to geo-chemical analysis and hydrology of their four permitted
sites in Montrose County. Per the Board's signed Stipulated Motion all parties have set dates to
accomplish review, submissions of response and final motions prior to the October 2007 Board Hearing.
A copy of the motion is also enclosed for your reference.
Of importance to Division staff is the August 29th, 2007 issuance of our final formal review of the new
data and its relationship to our original findings. Just as a refresher the SM-18 was determined not to be
a DMO, while the JD-6, JD-8 and JD-9 were.
The SM-18 historical data, site inspection and modeling showed that leachable constituents from waste
rock could not migrate through rock strata to the nearest aquifer within 1000 years and dilution would
further reduce concentrations to negligible amounts prior to aquifer interception. Surface impacts are
controlled by stormwater management which includes on site run-on and run-off diversions into
sedimentation catchments and retention ponds. Therefore, no reasonable data supported an impact to the
surrounding environment and DMO status appears not to be warranted. An environmental coalition has
appealed this finding.
The JD-6 and 8 models and reports did not have enough empirical data to support that any potential
migration of leachable constituents would not adversely affect human health, property or the
environment. Of specific issue was the lack of data concerning depth to water for groundwater aquifer
levels and overall quality. Here too, stormwater management practices have mitigated off site surface
impacts. Without the data on groundwater depth and quality, staff could not definitively say that there
was no impact to health, property or the environment and ruled that DMO status was justified. Cotter
has appealed this finding.
Office of Office of
Mined Land Reclamation ARive and Inactive Mines