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• • iii iiiiiiiiiiiu iii <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Depanmenl of NaNral Resources <br />1313 Sherman St., Room 215 r <br /> <br />Denver, Colorado 80203 ~ <br />~~~ <br /> <br />Phone: (3031 866-3567 I <br />FAX: 13031 032-8106 <br /> DEPARTMENT OF <br /> NATURAL <br /> RESOURCES <br /> Roy Romer <br /> Goeernor <br /> lames S LochheaA <br /> EKecmive Director <br /> hLChael 8. Lnng <br />DATE: June 24, 1994 orvision Director <br />TO: Berhan Keffelew/{~'~~'~`'`~ <br />FROM: Harry Posey sZ / <br />RE: Review: Geochemical evaluation of potential underdcain materials; <br />Commitment No. 36; Cripple Creek & Victor Gold; Cresson Project; Permit <br />No. M-80-244 <br />BACKGROUND <br />Commitment No. 36 covers testing of materials to be used for the Arequa Gulch Underdrain. <br />The testing for this commitment required verification that the materials would be durable, non- <br />slaking, and chemecally inert. Chemical inertness was to be measured using (a) the Meteoric <br />Water Mobility Procedure to simulate the soaking and flushing that might be anticipated under <br />a single storm event and (2) appropriate acid generation test. This review covers the chemical <br />testing portion of the Commitment No. 36 response. <br />The testing has proceeded on the assumption that the only metals of concern are those that are <br />applicable to the surface water discharge permits. A letter from B. Keffelew to CC&V, April <br />18, 1994, identifies some of the water quality parameters for which leaching data were needed. <br />CC&V tested ten samples from five wells for 29 parameters. Many of those parameters are not <br />regulatable either under surface water or groundwater programs of the Clean Water Act. These <br />will not be considered. <br />APPLICABLE STANDARDS <br />At issue is whether the water that will flow through the Arequa Gulch Waste Rock Underdrain <br />and the Valley Heap Leach Underdrain will be subject to surface water regulations, groundwater <br />regulations, or both. Surface and groundwater water flowing through the underdFain and into <br />