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~ • III IIIIIIIIIIIIIIII <br />STATE <br />Berhan Keffelew <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone 1303) 866-3567 <br />FAX: 130 31 832-8106 <br />i31c <br /> <br />OF COLORADO <br />~~ <br />DEPARTMENT OF <br />NATURAL <br />RESOURCES i <br />Roy Romer <br />Gorernor <br />DATE: June 27, 1994 <br />TO: <br />FROM <br />RE: <br />dames 5. Loc hhead <br />E~eCUhve DirpclOr <br />Michael B Long <br />DwiSion Director <br />Harry Posey <br />Review: Ironclad Mill ' ' gs, Reslts of Cyanide Detoxification Assessment <br />The repoA presents an interesting discussion of Nevada mining law as it regards re-use of <br />mining waste. Nevada regulations state that mine wastes may be re-used as mining materials <br />provided: <br />1. TCLP tests of the waste not exceed 100 times the MCL for any contaminant, and <br />2. that MWMP tests not exceed 10 times the MCL. <br />The Division of Minerals and Geology has determined that these tests are not appropriate for <br />many circumstances, do not account for the applicable water quality compliance criteria at the <br />Cresson Project, and aze not conservative for any circumstance. <br />The IZicion of MineraLc and Geology hac adnnted the~osition that TCLP tests are ~3nt <br />"appropriate for mining waste as they do not mimic the acids that are mngt likely rn he present <br />in min_ a wastes. The Division has also adopted the position that MWMP testing is applicable <br />only in cases where the material is subject to occasional flushing with meteoric water. Rocks <br />that are saturated frequently or constantly would not qualify for MWMP testing. The Division <br />is required to assure that acid and toxic producing materials, at their source, w' not be released <br />in quantities which will not meet compliance at the water quality compliance points established <br />by the Colorado DepaRment of Health. <br />While this approach is interesting and informative, CC&V must understand that the mining laws <br />of other states cannot supplant Colorado statutes. <br />RESULTS <br />Meteoric Water Mobility Procedure Testing <br />