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%EARDON MINING INDUSTRY CONSULTANTS <br />TEEL LLC 18050 COUNTY ROAD G • CORTEZ, CO 81321 • 970.565.0278 • MTOREARDONSTEEL.US <br />October 8, 2013 <br />Russ Means, Senior Environmental Protection Specialist RR;EIVED <br />Division of Reclamation, Mining and Safety <br />Grand Junction Field Office "OCT 0 $ 2013 <br />101 South 3`d St., Suite 301 GRAND JUN ,; , ELD OFFICE <br />DIVISION OF <br />Grand Junction, CO 81501 RECLAMATION PINING & SAFETY <br />RE: Camp Bird Mine, Permit M -1982 -090, Disagreement with Pending Designation as a <br />Designated Mining Operation <br />Dear Mr. Means, <br />On behalf of Camp Bird Colorado, Inc. (CBCI), Reardon Steel LLC (RSL) is providing the <br />Division of Reclamation, Mining and Safety (Division) with this letter as a follow up to our <br />meeting on October 1, 2013 and to formally respond to the Division's letter dated September 10, <br />2013 regarding the Division's pending designation of the Camp Bird Mine (M- 1982 -090) as a <br />Designated Mining Operation (DMO). The Division references Rule 7.2.1(1), which states the <br />determination of a DMO will be based on the criteria described in the definitions of a DMO <br />found in Rule 1.1(14). After careful consideration, CBCI respectfully disagrees with the <br />Division's determination that the current setting and level of approved activities at the Camp <br />Bird Mine meet the criteria of a DMO. <br />This letter presents CBCI's analysis of how the current permitted conditions at the Camp Bird <br />Mine do not meet the relevant criteria presented in paragraphs (a) through (f)(1) of Rule 1.1(14) <br />(i.e. the components of the definition of a Designated Mining Operation that are relevant for <br />comparison with the Camp Bird Mine). Following the analysis of Rule 1.1(14), this letter <br />provides a detailed discussion of CBCFs current water quality monitoring program, disposed <br />solids sampling program, and a generalized activity update of operations at the mine. <br />(a) DMO criteria: Designated chemicals used in metallurgical processing are present <br />on -site; <br />CBCI analysis: There are no designated chemicals, per Rule 1. 1(13), in the permit area <br />or approved to be in the permit area of the Camp Bird Mine. Designated chemicals are <br />not necessary for approved mining operations at the Camp Bird Mine. <br />(b) DMO criteria: toxic or acid - forming materials will be exposed or disturbed as a <br />result of mining operations; <br />CBCI analysis: Prior to resumption of mining operations in September 2012. the <br />permit area of the Camp Bird Mine had been reclaimed. The Division stated in its <br />observations provided in the August 29, 2011 inspection report under the subtitle Acid <br />