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~ 7-.3it~ <br />STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866.3567 <br />FAX: (3031832-8106 <br />'/ January 17, 2006 <br />~/To: Russ Means <br />From: Harry Posey, Kate Pickford ~~~~ <br />COLORADO <br />DIVISION OF <br />MINERALS <br />GEOLOGY <br />RECEA NATION•MINING <br />SAFETY•SCIENCE <br />Bill Owens <br />Governor <br />Russell George <br />Executive Direcror <br />Ronald W. Cattany <br />Division Director <br />Natural Resource Trustee <br />/RE: Review; Nov 3, 2005 reports and Nov 28, 2005 letter from GeoScience Services, re: <br />contaminant transport simulations for Uranium-vanadium ore bodies, Montrose County; <br />Cotter Corp., JD-6 Mine, M-1977-310; JD-8 Mine, M-1984-014, JD-9 Mine, M-1977-306, <br />& SM-18 Mine, M-1978-116 ~~ <br />------, <br />This review comprises our combined comments on the contaminant transport modeling <br />performed by GeoSciences Services for Cotter Corporation uranium-vanadium mines captioned <br />above. This review considers information from the above captioned reports, the letter, and a <br />phone conference call of January 4, 2066 with the operator and consultant. At issue is whether <br />the contaminant transport modeling, which was based on earlier-performed SPLP leach tests, <br />provides sufficient and conservative indications that any or all of the operations do not have a <br />potential to release acid or toxic substances. <br />Backuround: <br />"Acid or toxic producing materials' is a term defined in the Colorado Mined Land Reclamation <br />Act (C.R.S. 34.32-101 et seq.) {the Act) at section 103{1) as follows: <br />"Acid or toxic producing materials" means natural or reworked earth materials having acid or <br />toxic chemical and physical characteristics. <br />The Division considers toxic material, in this context, to be any dissolved constituent whose <br />concentration exceeds applicable groundwater quality standards as defined in Regulation 41 - <br />"The Basic Standards for Groundwater" -established by the Water Quality Control Commission <br />tWQCC). <br />The Act at 103{3.5) defines "designated mining operation" as follows <br />(a) "Designated mining operation" means a mining operation at which: <br />(I) Toxic or acidic chemicals used in extractive metallurgical processing are present <br />on-site; or <br />(II) Acid- or toxic-forming materials will be exposed or disturbed as a result of <br />mining operations. <br />(b) The various types of designated mining operations are identified in section <br />34-32-112.5. Such mining operations exclude operations which do not use toxic or acidic <br />chemicals in processing for purposes of extractive metallurgy and which will not cause acid mine <br />drainage. <br />Office of Office of Colorado <br />Mined Land Reclamation Active and Inactive Mines Geological Survey <br />