2009-01-21_HYDROLOGY - M1986176

• Permit No: M1986076
• IBM Index Class Name: HYDROLOGY
• Doc Date: 1/21/2009
• Doc Name: Failure to take required water quality samples
• From: DRMS
• To: DGMC
• Email Name: RCO
• Media Type: D
• Archive: No

(f DIVISION OF RECLAMATION, MINING AND SAFETY
"-Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
January 21, 2009
James Bender
-16. DGMC
5529 US Highway 64
Farmington, NM 87401
STATE OF COLORADO T.,
RacellC?
JAN t 1 10
01 a a Sa ry n,
pivisio
00
COLORADO
D I V I S I ON OF
RECLAMATION
MINING
SAFETY
Bill Ritter, Jr.
Governor
V
Re: Incas Mine Permit M-1986-176, Failure to Take Required Water Quality Samples.
Harris D. Sherman
Executive Director
Dear Mr. Bender,
Ronald W. Cattany
Division Director
Natural Resource Trustee
I received your 12/29/08 letter of response to my last inspection report (inspection date 10/30/08,
report date 11/11/08) in which you explained that the second set of required 2008 water samples were
not taken. As you are aware, the Incas Mine operates.under a DMO permit, and a requirement of the
Environmental Protection Plan (EPP) is that the water must be sampled to ensure that there is no
disturbance to the prevailing hydrologic balance. One set of samples consists of a groundwater sample
and a surface water sample, each to be taken from specific, approved locations. Two such sets of
samples are to be taken, one in summer and one in fall, during each year that there are active
operations at the site. The five parameters that must be analyzed in each and every sample consist of
pH, WAD cyanide, electrical conductivity, total dissolved solids, and sulfates, down to appropriate
detection limits.
The permit file reflects that the Incas Mine was active during part of 2008, and that the first set of
samples was taken during summer 2008, as required. However, the second set was not taken during
the fall, and the onset of winter weather and adverse ground conditions, prevented the taking of
samples. The effect of this is that there is a gap in the water analysis record, due to the lack of the late-
season, second set of 2008 analyses.
Checking the water analysis history in the permit file reveals that the water quality has remained
consistent and within acceptable limits for the five required parameters. It is important that the
sampling has occurred and will continue to occur at the specified and required times. Since the
Division is concerned about the missing samples, the Division feels that the operator must take the
next sample set as soon as the site is accessible and there is water available to sample. Depending on
spring conditions, this may occur before the summer samples are normally taken, but must be taken
whether the site is active or not. Beyond this, the Division cannot require anything more than for the
operator to resume sampling as required, in 2009 and future years, according to the Environmental
Protection Plan. Because the operation is a DMO, please ensure that all water quality samples are
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