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TR-12 Adequacy Review 2 15 June 2010 <br />Schwartzwalder Mine File No. M-1977-300 <br />The operator proposes to analyze representative samples of source term material from the alluvial <br />fill to evaluate the acid or toxic-forming potential if disposed of in the Minnesota adit underground <br />disposal area. Substantially greater detail for this plan is required and should be submitted as a <br />separate Technical Revision to facilitate field work this year, or in the Amendment that is due 01 <br />August 2010, if remedial activities will not be undertaken during this field season. Additional <br />required details shall include, but are not necessarily limited to, material toxicity, areas of <br />removal, disposal plans including proper assessment of options, final ground reclamation <br />details, stream protection during ground work, hydrologic barriers to prevent contamination of <br />water resources, and bonding. Material toxicity and disposal location relative to hydrological <br />interaction must also be assessed. <br />Item 3 <br />The proposed financial warranty unit costs are satisfactory but the total amount is inadequate. In <br />accordance with §34-32-117(4)(a) and (b) C.R.S. and Rule 4.2.1.(1),(2),(3) and (4), the operator <br />must provide financial warranty sufficient to account for the cost of water treatment plus the <br />pumping required to achieve the objective stated previously in Item 2 for the mine pool, for the <br />duration of treatment. A review of records also indicates that plugging and abandonment of <br />monitoring wells was not adequately addressed in past financial warranty calculations. Please <br />provide a detailed cost estimate for plugging and abandonment of all existing and proposed <br />monitoring wells, the total for which will be added to the required financial warranty. The division <br />continues to evaluate the reclamation liability associated with this revision and will finalize those <br />costs once responses to this adequacy letter are submitted. <br />Item 4 <br />The re-inclusion of the surface water monitoring stations to those stations already in the monitoring <br />program is adequate as submitted. Surface water monitoring should occur on a monthly basis until <br />further notice. The operator must also continue monitoring all existing ground water monitoring <br />wells on a quarterly basis until further notice. The analytes for surface water sampling should <br />include at a minimum those required by Paragraph 26 of the CDPHE Water Quality Control <br />Division Notice of Violation/Cease and Desist Order Number I0-100601-1. Analytes for ground <br />water sampling should include total dissolved solids, total alkalinity, nitrate + nitrite, sulfate, <br />chloride, fluoride, phosphorus, radium-226, gross alpha, and gross beta. Dissolved analytes should <br />include calcium, magnesium, sodium, potassium, aluminum, antimony, arsenic, barium, cadmium, <br />chromium, copper, iron, lead, manganese, molybdenum, selenium, thallium, uranium, and zinc. <br />Temperature, pH, and conductivity are to be measured in the field. <br />Please provide a table for inclusion with the permit that describes monitoring location, sample <br />site designation, sampling frequency and sampling parameters as indicated above. Please also <br />provide an updated map showing all surface and ground water sample locations included in the <br />monitoring plan.