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AM-02 EPP Adequacy Review 3 14 December 2010 <br />Schwartzwalder Mine File No. M-1977-300 <br />stabilization of other compounds, such as radium. This plan is also relevant to and included within <br />the requirements of Rule 6.4.21(6) - Designated Chemical(s) and Material(s) Handling. Through <br />the Division's Reason to Believe letter of 21 May 2010 and the MLRB Order of 11 August 2010, <br />the Board and Division have stated that capturing all of the potential mine pool discharge by way of <br />a passive treatment system installed in the alluvial fill area (AFA) is an unachievable scenario, <br />because the Board and Division believe that hydraulic communication along the Schwartz Trend to <br />Ralston Creek is inevitable, the intersection of which is at an approximate elevation of 6,400 feet <br />(USGS Ralston Buttes 7.5' topographical map), which is approximately 185 feet vertically below <br />the current elevation of the mine pool. The Board and Division will reject any plan based solely on <br />the premise of total capture of mine pool discharge by an AFA passive treatment system. This plan <br />must be submitted as a Technical Revision, separate from the Technical Revision required in <br />Adequacy Issue I.A. above for the mine dewatering, which will be due to the Division within 180 <br />days of the date of this letter (which will be 13 June 2011). <br />(2) In the event that decommissioning, stabilization, or detoxification of the mine pool is technically <br />unachievable, provide in that TR a plan for preventing excursions from the mine pool off site, <br />including the provision for locating and plugging of historical drill holes that may be acting as <br />conduits for migration of mine pool water to the AFA, as well as preventing migration through <br />geologic structures to receiving points downgradient, such as the intersection of the Schwartz trend <br />with Ralston Creek. <br />(3) Provide in that TR a mitigation plan in the event an excursion of contaminated water occurs. <br />The mitigation plan should include impacts to both surface water and ground water. <br />2) Rule 6.4.21(5 - Designated Chemicals Evaluation <br />In recent months, new activities have occurred under Technical Revisions TR-12 through TR-15, and <br />perhaps other additional activities that might have resulted in the introduction on site of designated <br />chemicals that may not have been included in the EPP that was submitted as TR-11. Please provide an <br />updated inventory of designated chemicals that takes into account the recent activities, in addition to <br />designated chemicals that would be required as part of expansion of the water treatment system to <br />include treatment of mine pool water. <br />3) Rule 6.4.21(6 - Designated Chemical(s) and Material(s) Handling <br />The Division has defined the unexcavated uranium-bearing rocks in the mine workings as toxic <br />materials because of their ability to leach uranium and other constituents into the mine pool water. <br />Therefore, in accordance with Rule 6.4.21(6) the operator must fully describe the procedures for the <br />disposal, decommissioning, detoxification, or stabilization of the toxic materials. Specifically, the <br />operator must provide a detailed plan for decommissioning or stabilization of the mine pool to prevent <br />off-site excursion, or a plan for detoxification of the mine pool such that if an excursion occurs it will <br />not adversely affect human health, property, or the environment. In accordance with Rule <br />6.4.21(6)(b)(iii), the operator must include a narrative description or plan that describes how they will <br />prevent adverse off-site impacts during periods of active mine site operations and periods of Temporary <br />Cessation.