2011-03-15_REVISION - M1981185

• Permit No: M1981185
• IBM Index Class Name: REVISION
• Doc Date: 3/15/2011
• Doc Name: Preliminary addequacy issues ‎(CN-01)‎
• From: DRMS
• To: R Squared Incorporated
• Type & Sequence: CN1
• Email Name: WHE
• Media Type: D
• Archive: No

Preliminary Adequacy Issues for CN-01 11
May Day Idaho Mine Complex
38. Attachment T-6 provides parameters and detection limits for analysis of surface water
samples. However, some of the parameters listed on Attachment T-6 indicate analysis
for dissolved metals, suggesting a ground water sample. Please provide a separate list
for surface and ground water parameters. As noted above, please ensure the list of
ground water parameters includes the full suite of parameters listed on Table 1 through
4 in CDPHE Regulation 41, Basic Standards for Ground Water. For surface water
sampling the Division requires all parameters on Tables I through III of CDPHE
Regulation 31, Basic Standards and Methodologies for Surface Water. If the Applicant
desires a variation from the full suite of parameters and detection limits listed in either
Regulation 31 or 41, please submit such request for Division review.
39. Pursuant to Rule 6.4.21(10)(a), please provide design specifications certified by a
licensed professional engineer for all Environmental Protection Facilities intended to
hold, convey, contain, or transport designated chemicals, including process solutions
and mill tailings containing designated chemicals. Please ensure the certified designs
address the redundant containment measures required under Rule 6.4.21(7)(e).
40. Please provide design specifications certified by a licensed professional engineer for all
Environmental Protection Facilities intended to capture and/or retain surface water run-
off from affected lands prior to its release from the mine-site into the natural water
drainage system, as required under Rule 6.4.21(10)(a)(iii). Such structures include, but
are not limited to, the augmentation pond and associated pipelines.
41. Operator responsibility for shipments of fuel, lubricants and chemicals commences at
the permit boundary. The transport route across the permit area includes steep road
grades, a crossing of the La Plata River, crosses wetlands and tributaries for the La Plata
River, and passes within approximately 100 feet of several domestic wells. Please
describe how fuel, lubricants, industrial chemicals and designated chemicals will be
transported from the mine entrance to the mill facility in a manner which protects
surface and ground water systems from an unauthorized release of pollutants and
protects off-site areas from damage.
42. The conceptual ground water model presented in Section 6.4.20(19) of Exhibit T does
not satisfy the requirements of Rules 6.4.21(19) and 3.1.7. Please revise the application
to appropriately address the requirements of Rule 6.4.21(9) and demonstrates how the
proposed operation will be compliant with Rule 3.1.7.
Pursuant to paragraph (3)(f) of the Joint Stipulation, the Applicant has agreed to address the
Division's adequacy issues at least two weeks prior to the decision date. Therefore, please
respond to the adequacy issues identified in this letter and in the three attached staff
memorandums from Peter Hays and Tim Cazier, no later than April 18, 2011. If additional time
is required to respond to these adequacy issues, please submit a written request for extension
of the review period.
Please contact me at the Division's office in Durango at 691 County Road 233, Suite A-2,
Durango, CO 81301, phone [phone], if you have any questions.