2010-01-12_REVISION - M1979181

• Permit No: M1979181
• IBM Index Class Name: REVISION
• Doc Date: 1/12/2010
• Doc Name: TR-02 Denied
• From: DRMS
• To: Mount Sneffels Mining Company and Grayling LLC
• Type & Sequence: TR2
• Email Name: WHE
• Media Type: D
• Archive: No

STATE OF COLOFADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203 CO L O RAD O
Phone: [phone] n t v t s t o N o f
FAX: [phone] RECLAMATION
MINING
SAFETY
DATE: 11 February 2010 Bill Ritter, Jr.
Governor
TO: Wally Erickson James B. Martin
Executive Director
FROM: David Bird - Geochemist
RE: Review of submittals, Ruby Trust Mine, File No. M-1979-181
I have completed a review of issues related to water quality and geochemistry for the TR-02 Adequacy
Review and the Solids Analysis for the Ruby Trust Mine submittals. The following additional adequacy
concerns related to the subjects of water quality and geochemistry need to be addressed, acknowledged, or
clarified:
Data Interpretation Methods, Pg. 5: Applicant states that the purpose of the data interpretation is "to
determine if the Ruby Trust mine setting produces toxic- or acid forming materials that could pose a
potential concern..."
DRMS response: Applicant is reminded that, under Rule 1.1(14)(b), toxic-forming materials need not be
produced to trigger the environmental protections specified in the Act and Rules for Designated Mining
Operations. They only need to be exposed or disturbed.
Table 2 - Ruby Trust Solids: DRMS would like to see additional details of the material sampled. Please
provide a description of the location of the samples on the ground, whether the sample was collected from in
situ material, drill cuttings/core, or an existing stockpile of previously removed rock. If the sample was
taken from the site, please show the sample location on a map. If the sample was taken from drill cuttings or
core, please provide a map showing the location of the drill hole. Please provide a photograph of each
material, before preparation, that was sampled and submitted for SPLP testing.
Table 5 and Table 8: Applicant presents the U.S. Environmental Protection Agency (EPA) Regulatory
Levels of 40 CFR § 261.24 as threshold criteria in the determination of whether site material "contains
sufficient concentrations of a given element at levels considered hazardous/toxic" based on the SPLP test.
DRMS Comment: 40 CFR § 261.24, which can be viewed at http://ecfr.gpoaccess.gov, refers only to EPA
Method 1311, the Toxic Characteristic Leaching Procedure (TCLP), and includes no reference to EPA
Method 1312, the Synthetic Precipitation Leaching Procedure (SPLP), as being applicable to the Regulatory
Levels presented. Method 1311 (TCLP) deploys a significantly more acidic extraction fluid than Method
1312 (SPLP). The TCLP uses an extraction fluid with pH 2.88 for extraction of non-volatile constituents
(Section 5.7.2 of the Method 1311 description, which is available at:
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines