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4) No new structures are expected. Currently, like at the JD-8, some ore is being pulled out <br />and stockpiled in a staging area. The stockpile pad is on top of the waste pile just west of <br />the maintenance shop. Berms along the waste pile edge prevent stormwater and <br />sediment from leaving the immediate area. Approximately 60 to 80 tons of ore where <br />noted stockpiled at this time. <br />5) The most current maps are from 1994. New maps will need to be done reflecting current <br />conditions, proposed impacts and proposed final reclamation configurations. <br />The Wright Group is covered under the SM-18 permit, which has just gone through an <br />amendment recently. Some issues covered here may impact those sites as well. <br />From the review and inspections staff has the following questions and recommendations: <br />A) New maps need to be generated showing current conditions, proposed impacts <br />such as extensions of waste piles, ore stockpile areas proposed final <br />reclamation configurations for all sites. Most maps are 10 years old or older. <br />Part of the, new mapping must include new boundary marking for the entire <br />site:. , <br />B) Annual reports need to. include a map showing yearly changes..ln most cases <br />Annual Reports have-not included a map for over 10. years.:Granted that there <br />hasn't been much change in that time period, but current activities necessitate <br />the more defined reports. Also, Annual Reports are still addressed to a person <br />(Ms. Mazza) who has not worked for the Division for a number of years. <br />C) Current rock waste has not been analyzed for geo-chemical constituents. The <br />JD-8, 8 and 9 and Wright Group are all in the same geological formation and <br />geographically close:- A composite sample from the.4 should provide the data <br />necessary to make an adequate analysis for the group. -The Wright Group is - <br />part of the SM-18 testing that has or will be submitted shortly to the Division. <br />D) Staff has a question for DMG engineers. The ore stockpile areas are on the <br />surface and exposed to the elements. Under current rules, that stockpiles are <br />okay if not in place for 180 days. However, if the site is continually in use <br />. - should measures be taken to prevent saturation of the site with ore fines and <br />other materials of concern and possible contamination? If.control measures <br />are needed, what should be required? Does DMG need a sample of the ore to <br />help answer questions in regard to control measure necessity? <br />E) Staff has asked for copies of the last 90 days worth of water sampling for the <br />CDPHE permit for review. None of the sites has identified seeps or springs <br />down gradient or in the immediate vicinity. Only one (JD-9) and possible a <br />second in the future (JD-8) require a discharge permit. Does DMG need <br />additional ground water monitoring at this time? <br />F) Staff has asked Cotter to review permit boundaries and possibly modify them <br />to reduce overlap. The JD-6 and Wright Group are basically one in the same <br />and the Wright Group and SM-18 are also enter twined. Staff review shows <br />that possible release of some site acreages covered under both permits to just <br />one could greatly clear up some confusion. However, Cotter may have <br />reasons for maintaining the acreage under both that is not apparent. <br />