2009-08-27_INSPECTION - M1990057

• Permit No: M1990057
• IBM Index Class Name: INSPECTION
• Doc Date: 8/27/2009
• Doc Name: Operator response review
• From: DRMS
• To: The Union Milling Company
• Inspection Date: 6/18/2009
• Email Name: PSH
• Media Type: D
• Archive: No

J DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
COLORADO
D IV IS I ON OF
RECLAMATION
MINING
SAFETY
August 27, 2009
Bill Ritter, Jr.
Governor
Harris D. Sherman
Executive Director
Michael Elder Ronald W. Cattany
Division
The Union Milling Company Natural Resource Trustee
J
7500 W. Mississippi Ave, Suite A170
Lakewood, CO 80226
Re: Calais Resources Colorado, Inc., Leadville Mill and Hopemore Shaft, File No. M-1990-057
June 18, 2009 Inspection Report Items 5 - Operator Response Review
Dear Mr. Elder:
./
The Division has reviewed the Operator's response to Item 5 of the June 18, 2009 inspection report for
the Leadville Mill and Hopemore Shaft, File No. M-1990-057, and submits the following comments.
The TCLP is not the appropriate testing method for mining sites. The TCLP method was developed
for assessment of leachate quality beneath landfills, hence the regulatory action levels are higher
than our state water quality standards. Please re-run a sample of the ore using the Synthetic
Precipitation Leaching Procedure (SPLP) method (EPA method 1312; ASTM method D6234-98). See
(http://www.phaseonline.com/tech updates/phasefact 07.html). The Division would also accept
the Meteoric Water Mobility Procedure (ASTM Method E2242-07). Evergreen Analytical has the
capability to do the SPLP. The Division is not aware of any local labs that do the MWMP.
The Division requests to be on site to witness the sample collection and ensure the sample is
representative, or at least see a whole rock analysis of the material to verify that it is indeed ore
and is representative.
2. The regulatory limits applied should be those of the State of Colorado Water Quality Control
Commission, not the TCLP Regulatory Action Levels. Refer to Table I, II, III in Regulation 31 for
surface water
(http://www.cdphe.state.co.us/regulations/wgccregs/100231wgccbasicstandardsforsurfacewater.
pdf), and Table 1, 2, 3, 4 in Regulation 41 for ground water
(http://www.cdphe.state.co.us/regulations/wgccregs/100241wgccbasicstandardsforgroundwater.
pdf). Regulation 31 is probably more relevant, since the threat to surface water might outweigh
the threat to ground water in that vicinity.
Office of
Mined Land Reclamation
Denver • Grand Junction • Durango
STATE OF COLORADO
Y?
Office of
Active and Inactive Mines