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Memo to G.R. Means 2 29 August 2011 <br />Review of EPP for JD -8 File No. M -1984 -014 <br />5) Section 5.2.2.1, pg. 8. Waste rock and ore are not designated chemicals nor do they generate <br />designated chemicals. They are regarded under Hard Rock Rule 1.1(1) as potentially Acid and <br />Toxic Producing Materials. However, under Rule 1.1(15), the definition of an Environmental <br />Protection Facility includes structures that are designed, constructed and operated for control or <br />containment of uranium, uranium by- products or other radionuclides, or toxic - forming materials. <br />6) Section 5.2.3.3. The Applicant should consult with the Division before conducting any <br />geochemical tests or any water monitoring program to obtain pre - approval of the test and the <br />analytes. Failure to do so may result in the testing parameters not meeting Division requirements <br />and the possibility of having to repeat portions of the tests. <br />The Applicant must commit to ongoing and periodic geochemical testing of ore and waste of <br />run -of -mine rock at a rate to be approved by the Division. Based on the current mine plan, the <br />Division recommends collecting sample suites for geochemical characterization of both ore and <br />waste at a rate of approximately every 50,000 tons of waste rock produced, or yearly, whichever <br />occurs more frequently. The material must be subjected to Acid -Base Accounting, Whole Rock <br />and SPLP testing. The SPLP analyte list must include every constituent in Tables 1 and 2 of the <br />Colorado Water Quality Control Commission Regulation No. 41, The Basic Standards for <br />Ground Water, with the following exceptions: Biological Parameters, Asbestos, Cyanide, <br />Nitrate, Nitrite (the combined Nitrate + Nitrite analysis is sufficient), Chlorophenol, Color, <br />Corrosivity, Foaming Agents, Odor, and Phenol. The analyte list must also include Vanadium, <br />Phosphorus and Hardness, and the physical parameters pH and Conductivity. <br />The Applicant must also commit to sampling any seepage that might arise from ore storage or <br />waste rock piles, and the analyte list must be as stated above. Field parameters such as pH and <br />conductivity must be measured in situ. <br />7) Exhibit G states that the uppermost aquifer is the Entrada formation, and that it lies between <br />120 and 270 feet below the ore zone. Also Table 20 on page 42 of the EPP indicates that the <br />Entrada "yields water." This formation is sufficiently close vertically to mine activity that the <br />protective measures of Hardrock Rules 3.1.7(1)(c), 3.1.7(2), 3.1.7(3)(a), 3.1.7(7)(a), 6.4.21(2), <br />and 6.4.21(8)(b) should apply. The Applicant should submit plans for the characterization and <br />protection of this water resource, including installation of a monitoring well in the Entrada <br />aquifer located in the vicinity of the mine at a location where impacts are most likely to occur, <br />baseline characterization as required in Rule 6.4.21(9)(b), and future monitoring. <br />