2010-04-20_REVISION - M1977300 ‎(2)‎

• Permit No: M1977300
• IBM Index Class Name: REVISION
• Doc Date: 4/20/2010
• Doc Name: Environmental Protection Plan ‎(EPP)‎ Adequacy Review #1
• From: Whetstone Associates
• To: DRMS
• Type & Sequence: TR11
• Media Type: D
• Archive: No

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Whetstone Division of Reclamation,
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Assoc/ateS Technical Memorandum
To: David Bird, Environmental Protecion Specialist, DRMS 4109C
From: Susan Wyman, P.E., P.G.
Date: April 16, 2010
Subject: Response to DRMS letter dated October 21, 2009 regarding
Schwartzwalder Mine Environmental Protection Plan Adequacy Review #1
The Environmental Protection Plan (EPP) for the Schwartzwalder Mine was prepared on August 7,
2009, submitted to the Colorado Division of Reclamation, Mining, and Safety (DRMS), and
designated as filed and complete on September 16, 2009. DRMS reviewed the EPP and issued a
letter on October 21, 2009 identifying 15 issues for revision and further clarification of the EPP.
Cotter and their consultants (Whetstone Associates and R2 Engineering) met with DRMS on March
19, 2010 to discuss revisions to the EPP and potential mitigation strategies for the site. The purpose
of this technical memorandum is to respond to the issues raised by DRMS in their October 21 letter.
Issues identified by DRMS are summarized in italics below.
1) The EPP is deficient with respect to Rule 64.20(1). The EPP must describe how the Operator
will assure compliance with the provisions of the Act and Rules in order to protect all areas that
have the potential to be affected by the toxic forming materials that have been identified on site,
while at the same time providing protections required under Rules 3.1.6 (Water - General
Requirements) and 3.1.7 (Groundwater - Specific Requirements)
The toxic forming materials that have been identified on site are:
(a) Radionuclides in the underground mine pool that are derived from the wallrocks of the
underground mine.
(a) Radionuclides in the Ralston Creek alluvium that threaten ground water and Ralston
Creek.
DRMS has determined that the contaminants in the mine pool present a potential hazard to human
health, property, and the environment because (1) the mine pool uranium concentration exceeds the
domestic water supply human health standard and the acute and chronic hardness-based aquatic life
standards and (2) the mine pool is still filling, albeit at a very slow rate that has become asymptotic,
and the predicted 2.06 gpm contribution from the mine pool to Ralston Creek via the Schwartz Trend
may not reflect long-term conditions that will prevail when the gradient reestablishes itself to steady
state.
Water levels in the mine pool appear to have stabilized at 23.7 feet below the Steve Level. Updated
water level information was discussed in the October 21 meeting, and is included in the revised EPP.
The hydrogeologic conceptual model for the mine pool has been clarified in the EPP, tested by
sampling in Ralston Creek sampling, and will be confirmed with the drilling of additional
monitoring wells. Bedrock in the area has extremely low permeability, and very little flow occurs.
Whetstone Associates, Inc.
243 N. Main St. ? Gunnison, Colorado 812306 Phone [phone] ? Fax [phone]