1. Provide access to the Willard waste rock pile by constructing a driveway. The driveway will also provide access to discharges from the Willard No. 1 adit and the Willard No. 2 adit.

    

2. Conduct geotechnical investigation of the Willard waste rock pile to confirm that foundation conditions are suitable for its use as a repository for other Removal Action mine wastes and for closing the pile in-place.

    

3. Remove the existing pond to reduce saturation of the Willard waste rock pile.

    

4. Route Illinois Gulch creek in the vicinity of the Puzzle Extension Shaft through culverts or into a lined channel to reduce leakage into the mine workings and decrease discharge from the Willard No. 1 adit.

    

5. Remove the Puzzle Extension Shaft waste rock pile and place it in the Willard waste rock repository.

    

6. Engage the Colorado Division of Reclamation, Mining & Safety (DRMS) to install a concrete plug in the Puzzle Extension Shaft.

    

7. Remove waste rock associated with the Cally adit and place it in the Willard waste rock repository.

    

8. Direct flow from Willard No.1 and Willard No. 2 adits to a new sedimentation pond to promote drying of iron-stained sediment in wet areas. Remove the iron-stained sediment and place it in the Willard waste rock pile repository.

    

9. Conduct soil sampling at residential properties, and possible remediation through soil removal/replacement if sampling results indicate remediation of residential properties is appropriate. Place any excavated soil in the Willard waste rock pile repository.

    

10. Close the Willard waste rock pile repository by grading to eliminate depressions, covering with clean soil, and revegetating.

     

11. Monitor the Willard No. 1 and Willard No. 2 adit discharges for 1-2 years and conduct tests to identify and assess potential passive water treatment approaches.

     

12. Based on monitoring and testing, and if found to be practicable, design, construct, and operate a passive water treatment system to address the Willard No. 1 and Willard No. 2 adit discharges.

The following are the Objectives for the Operational Period of July 12 to July 17, 2021:

• Install temporary collection and diversion system on Willard Adits 1 and 2.
• Begin construction of the Site access road (with appropriate drainage).
• Install environmental, erosion, and safety best management practices.
• Clear vegetation as needed from waste pile and begin grading.

The following are the current activities for the Operational Period of July 12 to July 17, 2021:

• Construction of the access road began on July 12, 2021.
• Installation of the temporary water diversion system was completed on July 13, 2021.
• Clearing and grubbing of the vegetation on the waste pile was completed on July 13, 2021 and re-grading is now underway.
• Site BMPs were installed on July 12, 2021.

For the next Operational Period, the removal team will be continuing with the follow activities:

• Remove metals ladened sediment from drainage paths around the waste pile and in Iron Gulch.
• Pump the pooled water in front of Willard Adit 2 to evaluate the water seepage from the adit to the adjacent wetland.
• Finish the access road including the installation of 3 culverts.
• Complete the rough grade of the waste pile.

The following are the Objectives for the Operational Period of July 19 to July 23, 2021:

• Continue construction of the Site access road (with appropriate drainage).
• Clear vegetation as needed from waste pile and continue grading.
• Maintain the temporary collection and diversion systems on Willard Adits 1 and 2.
• Maintain environmental, erosion, and safety best management practices

The following are the current activities being conducted for the Operational Period of July 19 to July 23, 2021:

• Compaction of the access road is currently underway.
• Installation of two 36” culverts beneath the access road completed on July 21, 2021.
• Clearing and grubbing of the vegetation on the waste pile was completed on July 19, 2021.
• Re-grading of the Willard waste pile is currently underway.

For the next Operational Period, the removal team will be continuing with the following activities:

• Remove metals ladened sediment from the drainage paths around the waste pile and in Iron Gulch.
• Finish the access road including the installation of 2 more culverts.
• Complete the rough grade of the waste pile and begin cut to fill.
• Stabilization of soil at the North West side of the Willard waste rock pile (tentative on the soil composition and strength at the North West toe of the waste rock pile).

The following are the Objectives for the Operational Period of July 26 to July 30, 2021:

• Continue construction of the Site access road (with appropriate drainage).
• Continue grading of Willard waste rock pile.
• Clearing and grubbing for the access road as necessary.
• Maintain the temporary collection and diversion systems on Willard Adits 1 and 2.
• Maintain environmental, erosion, and safety best management practices.

The following are the current activities being conducted for the Operational Period of July 26 to July 30, 2021:

• Construction of the access road on the North East side of the wetland is currently underway.
• Installation of two 12” culverts completed on July 26.
• Grading of the Willard waste pile is currently underway to allow for the stabilization of the soil at the Northern toe of the waste pile.

For the next Operational Period, the removal team will be continuing with the following activities:

• Finish the access road with adequate drainage.
• Grade the Northern face of the Willard waste pile to allow access for the excavator.
• Begin excavation of Northern toe of the Willard waste pile to allow the installation of Geo-mat, Geo-fabric and stabilizing rocks.

The following are the Objectives for the Operational Period of August 2 to August 6, 2021:

• Finish the construction of the Site access road (with appropriate drainage).
• Removal and relocation of peat at the Northern toe of the Willard waste rock pile.
• Begin installation of stabilizing geofabric and rocks at the Northern toe of the Willard waste rock pile.
• Continue grading of Willard waste rock pile.
• Maintain the temporary collection and diversion systems on Willard Adits 1 and 2.
• Maintain environmental, erosion, and safety best management practices.

The following are the current activities being conducted for the Operational Period of August 2 to August 6, 2021:

• Construction of the access road and culverts was completed on August 4.
• Peat and soil at the Northern toe of the Willard waste rock pile has been moved to install Geo fabrics and stabilizing rock.
• Installation of geo fabric and rocks at the northern toe of the Willard waste rock pile is currently underway.
• Peat removed from the northern toe of the Willard waste pile is currently being dried and relocated South East of the Willard waste pile.
• The Cally waste rock pile has been moved and graded into the Willard waste pile.
• Grading of the Willard waste pile is currently underway.

For the next Operational Period, the removal team will be continuing with the following activities:

• Continue installation of stabilizing geo fabrics and rocks at the Northern toe of the Willard waste rock pile.
• Relocate removed and dried peat to the pond South East of the Willard waste rock pile.
• Continue grading of Willard waste rock pile.

The following are the Objectives for the Operational Period of August 9 to August 13, 2021:

• Continue the Removal and relocation of peat at the Northern toe of the Willard waste rock pile.
• Continue installation of stabilizing geofabric and rocks at the Northern toe of the Willard waste rock pile.
• Continue grading of Willard waste rock pile.
• Maintain the temporary collection and diversion systems on Willard Adits 1 and 2.
• Maintain environmental, erosion, and safety best management practices.

The following are the current activities being conducted for the Operational Period of August 9 to August 13, 2021:

• Peat and soil at the Northern toe of the Willard waste rock pile has been moved to install Geo fabrics and stabilizing rock.
• Continued Installation of geo fabric and rocks at the northern toe of the Willard waste rock pile.
• Continued Grading the Willard waste rock pile.

For the next Operational Period, August 16 through August 20, 2021, the removal team will be continuing with the following activities:

• Continue installation of stabilizing geo fabrics and rocks at the Northern toe of the Willard waste rock pile.
• Relocate removed and dried peat to the pond South East of the Willard waste rock pile.
• Continue grading of Willard waste rock pile.

The following are the Objectives for the Operational Period of August 16 to August 20, 2021:

• Continue grading of Willard waste rock pile.
• Regrade Southern pond slope and drainage channel.
• Proceed with construction of future sediment pond
• Maintain the temporary collection and diversion systems on Willard Adits 1 and 2.
• Maintain environmental, erosion, and safety best management practices.

The following are the current activities being conducted for the Operational Period of August 16 to August 20, 2021:

• Southern pond area has been regraded and drainage channel reshaped and filled. 
• Reinforced the toe of the North and Northwest berm of the future sediment pond
• Regrading pad area to continue constructing pond area
• Continued Grading the Willard waste rock pile.

For the next Operational Period, August 23 through August 27, 2021, the removal team will be continuing with the following activities:

• Cap  with clay/topsoil and finalize regrading and construction of pond area
• Begin excavation of the creek adjacent to the Puzzle shaft in preparation for headwall installation
• Continue reinforcing the toe of North and Northwest berm of future sediment pond

The following are the Objectives for the Operational Period of August 23 to August 27, 2021:

• Proceed with construction of future sediment pond including preparation for placing outlet structure.
• Prepare for culvert and headwall installation at the Puzzle Mine Extension Shaft including diverting creek and digging footers.
• Maintain the temporary collection and diversion systems on Willard Adit 1.
• Maintain environmental, erosion, and safety best management practices.

The following are the current activities being conducted for the Operational Period of August 23 to August 27, 2021:

• Diverted water from creek and began shaping channel adjacent to the Puzzle Mine Extension Shaft.
• Prepared for culvert and headwall installation at Puzzle Mine Extension Shaft.
• Completed final grading of the future sediment pond.
• Prepared for liner installation at sediment pond including painting outlet structure with epoxy and installing discharge piping.
• Maintained the temporary collection and diversion system on Willard Adit 1.
• Maintained environmental, erosion, and safety best management practices.

For the next Operational Period, August 30 through September 3, 2021, the removal team will be continuing with the following activities:

• Pour concrete headwalls at the Puzzle Mine Extension Shaft.
• Continue preparing for liner installation at the future sediment pond, including piping and outfall installation.
• Maintain the temporary collection and diversion system on Willard Adit 1.

The following are the Objectives for the Operational Period of August 30 to September 3, 2021:

• Pour concrete headwalls and set piping in the channel adjacent to the Puzzle Mine Extension Shaft.
• Continue preparing for liner installation at the future sediment pond.
• Maintain the temporary collection and diversion system on Willard Adit 1.
• Maintain environmental, erosion, and safety best management practices.

The following are the current activities being conducted for the Operational Period of August 30 to September 3, 2021:

• Maintained water diversion from creek adjacent to the Puzzle Mine Extension Shaft.
• Set piping and junction box in channel adjacent to the Puzzle Mine Extension Shaft.
• Set and poured concrete headwalls in channel adjacent to the Puzzle Mine Extension Shaft.
• Prepared for liner installation at sediment pond including outlet structure and piping installation and spill way construction.
• Stockpiled clean fill for Willard waste rock pile cap.
• Maintained the temporary collection and diversion system on Willard Adit 1.
• Maintained environmental, erosion, and safety best management practices.

For the next Operational Period, September 6 through September 10, 2021, the removal team will be continuing with the following activities:

• Fill and set piping in channel adjacent to Puzzle Mine Extension Shaft.
• Construct rip rap apron at bottom of channel adjacent to Puzzle Mine Extension Shaft.
• Remove waste rock from Puzzle Mine Extension Shaft to Willard waste rock pile.
• Complete berming and outlet box installation at Willard Adit 2.
• Install sediment pond liner and prepare for diversion piping installation from Willard Adits 1 and 2 to pond.  

The following are the Objectives for the Operational Period of September 6 to September 10, 2021:

• Complete the liner installation at the future sediment pond.
• Backfill the head wall area and re-divert water from the temporary collection and diversion system at the Puzzle Mine Extension shaft.
• Maintain the temporary collection and diversion system on Willard Adit 1.
• Maintain environmental, erosion, and safety best management practices.

The following are the current activities being conducted for the Operational Period of September 6 to September 10, 2021:

• Fill and set piping in channel adjacent to Puzzle Mine Extension Shaft.
• Complete the liner installation at the future sediment pond.
• Complete the installation of diversion piping into the future sediment pond.
• Maintained environmental, erosion, and safety best management practices.

For the next Operational Period, September 13 through September 17, 2021, the removal team will be continuing with the following activities:

• Backfill temporary channel used to divert water at the Puzzle Mine Extension Shaft.
• Backfill Illinois Gulch lined channel.
• Install sediment pond liner and prepare for diversion piping installation from Willard Adits 1 and 2 to pond.

The following are the Objectives for the Operational Period of September 13 to September 17, 2021:

• Install vegetation and landscape screen surrounding the sediment pond.
• Begin installing drainage piping from Willard Adit 2.
• Maintain the temporary collection and diversion system on Willard Adit 1.
• Finish excavation of Puzzle Mine shaft.
• Maintain environmental, erosion, and safety best management practices.

The following are the current activities being conducted for the Operational Period of September 13 to September 17, 2021:

• Began installing vegetation and landscape screen surrounding the sediment pond.
• Installed drainage piping from Willard #2 Adit to the sediment pond.
• Finished excavation of Puzzle Mine shaft.
• Finished backfilling Illinois Gulch lined channel.
• Maintained environmental, erosion, and safety best management practices.

For the next Operational Period, September 20 through September 24, 2021, the removal team will be continuing with the following activities:

• Prepare concrete to plug Puzzle Mine shaft.
• Continue installing drainage pipe from Willard #2 Adit to the sediment pond.
• Finish installation of vegetation and landscape screen surrounding the sediment pond.

The following are the current activities being conducted for the Operational Period of September 20 to September 24, 2021:

• Continued installation of drainage pipe from Willard #2 Adit.
• Added topsoil to the surrounding area of the sediment pond.
• Finished plugging Puzzle Mine shaft and added topsoil to the surrounding area.
• Drilled holes within soil for fence post installation surrounding sediment pond.
• Maintained environmental, erosion, and safety best management practices.

For the next Operational Period, September 27 through October 1, 2021, the removal team will be continuing with the following activities:

• Create drainage channel between Willard #1 Adit and sediment pond.
• Spread temporary vegetation seeding on topsoil surrounding the sediment pond.
• Begin installation of fence surrounding the sediment pond.
• Install road base for the parking lot and access road near the sediment pond.

The following are the Objectives for the Operational Period of September 27 to October 1, 2021:

• Complete installation of fencing that will surround the sediment pond.
• Finish installation of the drainage pipe from the Willard #2 Adit to the sediment pond.
• Create drainage channel between Willard #1 Adit and sediment pond.
• Maintain environmental, erosion, and safety best management practices.

The following are the current activities being conducted for the Operational Period of September 27 to October 1, 2021:

• Finished installation of drainage pipe from Willard #2 Adit.
• Created drainage channel between Willard #1 Adit and sediment pond.
• Installed fencing surrounding sediment pond.
• Maintained environmental, erosion, and safety best management practices.

For the next Operational Period, October 4 through October 8, 2021, the removal team will be continuing with the following activities:

• Spread hydroseed on topsoil surrounding the sediment pond and at the Puzzle Mine shaft.
• Complete final grading of access road near the access road entrance.
• Install road base for the parking area and access road near the sediment pond.

The following are the Objectives for the Operational Period of October 4 to October 8, 2021:

• Spread hydroseed on topsoil surrounding the sediment pond and at the Puzzle Mine shaft.
• Complete final grading of access road near the access road entrance.
• Install road base for the parking area and access road near the sediment pond.
• Maintain environmental, erosion, and safety best management practices.

The following are the current activities being conducted for the Operational Period of October 4 to October 8, 2021:

• Hydroseed has been spread on the topsoil surrounding the sediment pond, access road, and at the Puzzle Mine shaft. 
• Completed final grading of access road near the access road entrance.
• Installed road base for the parking area and access road near the sediment pond.
• Demobilizing crew and equipment from the Site.

For the next Operational Period, October 9, 2021 to October 29, 2021, the removal team will be continuing with the following activities:

• Install a closure gate at the access road entrance.
• Install catwalks at the sediment pond.
• Complete demobilization of equipment from the Site.

The following are the Objectives for the Operational Period of October 9, 2021 to October 29, 2021:

• Install outlet structure stop logs and catwalk at the sediment pond.
• Install flume at the sediment pond outfall.
• Install a closure gate at the access road entrance.
• Complete demobilization of equipment from the Site.

The following are the current activities being conducted for the Operational Period of October 9 to October 29, 2021:

• Completed installation of stop logs on the outlet structure and catwalk at the sediment pond.
• Completed installation of flume on sediment pond outfall.

Due to shipping delays, the closure gate will be installed during the next Operational Period.

For the next Operational Period, October 30, 2021 to November 8, 2021, the removal team will be continuing with the following activities:

• Install a closure gate at the access road entrance.
• Complete demobilization of equipment from the Site.

The following are the Objectives for the Operational Period of October 30, 2021 to November 8, 2021:

• Complete sealing of stop log brackets to the outlet structure.
• Install a closure gate at the access road entrance.
• Complete the demobilization of equipment from the Site.

The following are the current activities being conducted for the October 30, 2021 to November 8, 2021:

• Completed the sealing of stop log brackets to the outlet structure.
• Installed a closure gate at the access road entrance.
• Completed the demobilization of equipment from the Site.

Work is completed for the season at the Illinois Gulch Site. Monitoring and maintenance activities and development of a water treatment plan will begin in Spring of 2022.