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1q/?77--3 0 49 --- <br />Z S Tawe oeio `i <br /> <br />Rationale for Not Conducting Mine Dewatering and Mine Water Treatment <br />at the Schwartzwa er Mine <br />by Susan A. Wyman, P.E., P. G., Whetstone Associates <br />Groundwater levels in the Schwartzwalder Mine have recovered to 6,557 ft above mean sea level (amsl) <br />since the underground pumps were shut off in May, 2000. A May 19, 2010 letter from the Colorado <br />Division of Reclamation, Mining, and Safety (DRMS) contained Corrective Action #2 which said to <br />reinitiate mine dewatering and pump the mine pool down to at least 500 feet below the Steve Level (that is, <br />to approximately 6,102 ft amsl or below) and to treat the water pumped from the mine pool to meet water <br />quality standards prior to discharge into Ralston Creek. Cotter and its technical consultants believe that <br />pumping down the mine pool and treating the water would be ineffective and impractical for the reasons <br />described below. <br />If minor amounts of water from the mine pool are exiting the mine, the water would reach the alluvium and <br />fill where it will be collected at Sump I and treated in the new water treatment system. <br />Cotter and its contractors are working to install pumps, piping, and a new water treatment system to capture <br />and treat groundwater in the alluvium and fill. Groundwater in the alluvium reports to Sump 1, and if not <br />intercepted at the sump, the water reports to the creek. Cotter will begin actively treating groundwater in <br />the alluvium by July 31, 2010, at the latest. All the available groundwater from Sump 1 will be pumped to <br />the water treatment plant where an ion exchange system is being installed by a water treatment contractor. <br />The treatment system is sized for a nominal flow rate of 100 gpm, with a maximum of 150 to 200 gpm, and <br />will be capable of treating all of the water collected from Sump 1. The treatment system can also be <br />expanded. Cotter is committed to this corrective action, which is expensive, and has allocated significant <br />resources and personnel with the intent of starting treatment before July 31, 2010. <br />Corrective action at the site should focus on identified sources of loading to Ralston Creek. There is no <br />direct evidence that the mine pool is contributing uranium to Ralston Creek. In contrast, the alluvium and <br />fill were recognized as a source of loading after the sumps were shut down and before the mine pool rose to <br />an elevation above the creek level. (Note that the "first flush" of uranium from the alluvium and fill was <br />followed by a significant decrease to below drinking water standards. In subsequent years, seasonal spikes <br />in uranium concentrations in Ralston Creek have been followed by steep declines, such as in the most <br />recent (April 2010) sampling results (Table 1, Attachment 1). The initial trend in uranium concentrations <br />was downward after the "first flush". Due to this trend and to seasonality in creek concentrations, the need <br />for water treatment in groundwater from the alluvium and fill was not immediately recognized.) <br />Table 1. Uranium in Ralston Creek, April 2010 <br />Date Sample Station Analyte Result Units <br />4/14/2010 AWD Uranium, dissolved 0.001 mg/L <br />4/14/2010 A001 Uranium, dissolved 0.003 mg/L <br />4/14/2010 BPL Uranium, dissolved 0.034 mg/L <br />4/14/2010 FBRG Uranium, dissolved 0.034 mg/L <br />4/14/2010 ARH Uranium, dissolved 0.037 mg/L <br />4/14/2010 LLHG Uranium, dissolved 0.036 mg/L <br />Source: Energy Laboratories. See attachment 1 for complete analytical results. <br />Whetstone Associates, Inc. <br />243 N. Main St. ? Gunnison, Colorado 81230 6 Phone 970-641-7471 ? Fax 970-641-7431