1995-11-29_REVISION - M1977493 - Laserfiche WebLink

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Letter to Jay Jones -7- November 29, 1995 definitive plan to address these issues. Obviously any improvements in the way that acid rock and acid mine drainage are handled at the site, particularly methods emphasizing pollution prevention, should be incorporated into the EPP at the appropriate time. Also, it is the Division's view that the geochemistry of the waste rock that is and will be used as a plant growth medium for reclamation at several site locations should be further evaluated. This evaluation should investigate the suitability of the waste rock for sustaining plant growth, and should result in the development of soil amendment specifications to enhance vegetation establishment. The Division recognizes that assessment of waste rock as a plant growth medium will, and should be an on-going process, but requests that Climax commit to plant growth medium evaluation and reporting as a component of the geochemical evaluation described in the EPP application. 14. In section 4. 1.2.2 of the EPP the statement is made that upon final closure of the mine, ponded water on the tailing impoundments will be managed according to conditions of the CDPS Permit. Please note that maintenance of free water ponds on the tailing impoundments as a reclamation feature would require a Reclamation Permit modification, as the current permit stipulates that the impoundments will be sloped to be free-draining. 15. In section 5. 1.2 of the EPP application it is stated that reclamation of the Storke Yard is considered an Environmental Protection Facility in the passive sense, and that once reclamation is completed and established, seepage and storm water/snowmelt runoff should be reduced and will be specifically routed to the Arkansas River or to the pump station if testing indicates the presence of contamination. What numeric protection levels will be applied to the tests to determine if runoff can be routed to the river? What contaminants will the testing and analysis target? 16. In section 5.2. 1 of the EPP application, the statement is made that the tailing contains enough sulfur to be acknowledged by Climax as slightly acid producing. Analytical results of some tailing analyses are included in Appendix C to the EPP application. It is the Division's view that the information provided on the geochemistry of the tailing material is insufficient to assess the degree to which the tailing may be acid producing. You may either provide sufficient data to substantiate the qualified statement that the tailing is slightly acid producing, or withdraw the qualifier. 17. Section 5.3 .2 of the EPP application indicates that any contaminants that might be released from potential sources in the Tenmile Creek watershed (except for fugitive dust) would be captured above or at the Mayflower impoundment where water is treated prior to discharge. It is the Divisions view that the potential for ground water discharges from contaminant sources in the Tenmile Creek watershed