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Mr. Means/M- 1982- 090/Disagreement with Pending DMO <br />October 8, 2013 <br />Page 2 of 5 <br />and Toxic Materials, that "all ore and contaminants were removed during the <br />reclamation a few years ago ". CBCI concurs with the Division's observations, and <br />further states that there are no acidic or toxic - forming materials in the permitted area. <br />The approved development activities in the permit area do not warrant or allow the <br />introduction of toxic or acid - forming materials to the permit area. <br />(c) DMO criteria: acid mine drainage occurs or has the potential to occur due to <br />mining or reclamation activities; <br />CBCI analysis: As stated above, the Division has acknowledged in its recent inspection <br />reports that materials that could have had the potential for acid mine drainage were <br />removed from the permit area several years ago. Further, the Division acknowledges <br />that the mine discharge was found to meet discharge standards and that no seepage or <br />stained discharge occurs in the permit area. Under the current approved development <br />activities CBCI is not allowed to introduce materials in the permit area that could cause <br />acid mine drainage to the surrounding environment. CBCI voluntarily proposed <br />safeguards in Technical Revision 4 (TR -04), which were approved by the Division, to <br />ensure that; 1) the water quality at the site would remain stable and unaffected while <br />approved activities in the permit area were on- going, and 2) solids materials brought to <br />surface under the current approved activities would not contain acid or toxic - forming <br />materials. Please refer to the discussions in this letter regarding Water Quality <br />Monitoring and Disposed Solids Sampling. <br />(d) DMO criteria: uranium is developed or extracted, either by in situ leach mining <br />methods or by conventional underground or open mining techniques; <br />CBCI analysis: Uranium is not developed or extracted by any means at the Camp Bird <br />Mine. <br />(e) DMO criteria: ...designated mining operations exclude operations that do not use <br />toxic or acidic chemicals in processing for purposes of extractive metallurgy and <br />will not cause acid mine drainage...; <br />CBCI analysis: Extractive metallurgical processes are not approved activities within <br />the permit area of the Camp Bird Mine. Consequently, no toxic and acidic chemicals <br />for these processes are on site or are allowed to be on site. <br />(fl) DMO criteria: Metal mining operations, permitted under Section 34 -32 -114 <br />C.R.S. 1984, as amended, which do not use or store designated chemicals, shall be <br />exempted from the requirements applicable to Designated Mining Operations, <br />unless they have potential to produce acid or toxic mine drainage in quantities <br />sufficient to adversely affect a person, property or the environment. It shall be the <br />burden of the Operator or Applicant to demonstrate to the satisfaction of the <br />Office that such potential does not exist. <br />CBCI analysis: As stated before, designated chemicals per Rule 1.1(13) are not <br />allowed to be stored or used in the permit area. All ore and other contaminants which <br />could have had the potential to produce acid or toxic mine drainage were removed from <br />I�r_, _�_ <br />