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999 5TATE OF COLORADO <br /> DIVISION OF MINERALS AND GEOLOGY <br /> Department of Natural ReSourceS <br /> I t I i Sherman tit.. Room 215 <br /> Dem.er,Colorado 80203 D IV IS I ON OF <br /> Phone:(103,8M-3567 MINERALS <br /> IA\ 1;01)8328106 $c <br /> GEOLOGY <br /> RECLAMATION <br /> April28, 1999 MINING-SAFETY <br /> To: Chris Kamnikar, James Stevens BIII Owens <br /> (,overnor <br /> Q( G,,e E Vv r 1,he, <br /> From: James Dillie }I E`e`nI""D'r°"°r <br /> / Mwhael B long <br /> Di�nion Dim tur <br /> Re: Quick Review of April 28, 1999 Adequacy Letter, T.R.-03, Permit M-74-052 <br /> Per your request, I reviewed your adequacy letter which, I think, addresses the majority of <br /> Division concerns. <br /> The operator should be aware of Rule 3.1.7(4)(e) which states, in part, that the Division cannot <br /> approve a permit revision unless such permit or modification includes conditions adequate to <br /> implement all groundwater quality standards. Or, in this case, possibly groundwater and surface <br /> water standards. <br /> Also, the operator must comply with Rule 3.1.5(9) which states, in part, that the backfill material <br /> must be clean and inert (non-acidic and/or non-toxic producing). It does not appear that the <br /> operator has demonstrated to the Division's satisfaction that the flyash material is inert. Unless, <br /> or until, the operator demonstrates that the flyash is inert, I don't believe I would approve this <br /> T.R. <br /> I think Harry has the right idea; "the flyash disposal facility should be protected from contact <br /> with meteoric water through placement in a RCRA-type facility with leak detection, leak <br /> collection and rigorous monitoring." Something similar to a lined landfill facility. This is based <br /> on the comments by Harry regarding the leach test results. <br /> By the way, the operator is not doing us any favors by commiting to contact the "DMG <br /> immeadiately should the monitoring indicate an unacceptable degradation of groundwater <br /> quality." Pursuant to Rule 3.1.7(9), the operator is required to notify the Division within 5 <br /> working days when there is evidence (water sample test result) of groundwater discharges <br /> exceeding applicable standards. <br /> In addition, I would be concerned how the buried flyash will affect the aquifer. Will it act as an <br /> aquatard/barrier which possibly could alter the flow regime? Will the flyash mobilize and plug <br /> the porous and permeable media downgradient of the backfilled area? <br /> I believe your T.R. is a long way from being approved. Too many unanswered questions, not <br /> enough data. However, I think you are proceeding in the right direction. <br />