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Memo to G.R. Means 2 12 September 2011 <br />Review of 110(d) Application File No. M- 2011 -044 <br />any potential ground or meteoric water." The Applicant should indicate how they plan to ensure <br />that the material will not come in contact with ground or meteoric water. <br />6) Rule 6.4.21 Exhibit U — DMO EPP: Section U(6.a.2a) Reclamation of Decline Portal states: <br />"The Prince Albert Mine decline adit and approach ramp will be backfilled with approximately <br />1000 cubic yards of waste material." The Applicant is advised that all mine development waste <br />rock, whether disposed of above ground or in the underground workings, must be subjected to <br />geochemical characterization. The Applicant must conduct geochemical testing on <br />representative samples of all waste rock, and the testing should include at a minimum whole rock <br />analysis and an accelerated weathering procedure such as the SPLP. The sampling must be <br />representative of all material that could potentially be placed in permanent underground or <br />surface disposal areas. The criteria that define representative material must be determined in <br />consultation with the Division, such as sampling density, frequency, location and geochemical <br />character. <br />The analyte list for SPLP leachate 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 parameters pH and Conductivity. <br />Future geochemical characterization programs must be developed in consultation with the <br />Division. Failure to do so may result in the testing parameters not meeting Division <br />requirements and the possibility of having to repeat portions of the tests. <br />7) Rule 6.4.21 Exhibit U — DMO EPP: Section U(7.b) Ground Water Quality and Manage- <br />ment. Information provided in the application indicates that the Kayenta formation is the <br />uppermost aquifer in the mine area. This formation is sufficiently close vertically to mine <br />activity that the protective measures of Hardrock Rules 3.1.7(1)(c), 3.1.7(2), 3.1.7(3)(a), <br />3.1.7(7)(a), 6.4.21(2), and 6.4.21(8)(b) should apply. In order to provide compliance with Rule <br />6.4.21(8)(b) which requires the operator to "identify all known aquifers and related subsurface <br />water bearing fracture systems within two (2) miles of the affected lands ", the Applicant should <br />submit plans for the characterization and protection of this water resource, including installation <br />of a monitoring well in the Kayenta formation in the vicinity of the mine, baseline characteriza- <br />tion as required in Rule 6.4.21(9)(b), and future monitoring. In addition to completion as a <br />monitoring well, the drillhole should be used to gather data to delineate the aquifer and <br />determine the depth of water beneath the waste rock piles as required by Rule 6.4.21(8)(b). <br />Additional information should include data on the hydraulic gradient, general direction and rate <br />of flow, and geologic information needed under Rule 6.4.21(8)(c) by way of geologic logging <br />from ground surface down to total depth. The well screen should be only in the Kayenta and not <br />extend into overlying or underlying formations. Collection of water level and water quality data <br />should begin immediately after development of the well, but the collection of the five quarters of <br />