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Mr. Means/M- 1982- 090/Disagreement with Pending DMO <br />October 8, 2013 <br />Page 3 of 5 <br />the permit area several years ago. While current approved activities are on- going, no <br />acid or toxic - forming materials are allowed to be introduced into the permit area. The <br />water quality monitoring and disposed solids sampling programs provide safeguards to <br />ensure that CBCI complies with these restrictions. Therefore, CBCI believes that the <br />Division should make the determination that the Camp Bird Mine does not meet the <br />criteria of a DMO. <br />Water Quality Monitoring <br />On August 13, 2012, CBCI submitted Technical Revision 4 (TR -04) to the Division, which was <br />approved on September 20, 2012. Prior to this date, the site was in final reclamation and no <br />mining activities were allowed at the site. Activities proposed under TR -04 included re- <br />excavation of the historic settling pond, construction of a permanent pipe conveyance to carry <br />the portal discharge to the settling pond, temporary grading of gently sloped areas for equipment <br />and supplies storage, construction of a permanent surface shop, construction of a permanent <br />snow shed to cover a newly constructed surface rail system, excavation and permanent repair of <br />the collapsed mine portal, and rehabilitation of 14,000 feet of the 14 Level drift of the Camp Bird <br />Mine. Inclusive with TR -04, CBCI included water quality data from the mine discharge dating <br />from 1995 through 2012, which indicated that the water quality from the portal was stable. In <br />addition to providing this data, CBCI proposed a water quality monitoring program to implement <br />while the new mining activities approved under TR -04 were underway, whereby the portal <br />discharge would be monitored every 2 months and surrounding stream locations would be <br />monitored quarterly in order to establish a more robust background hydrologic condition. <br />Prior to approval of TR -04, the Division stipulated in its adequacy response letter dated August <br />30, 2012, that "...no mining may occur until such time that the hydrologic baseline conditions <br />are established ". That letter along with a subsequent letters from the Division on August 31 and <br />September 20, 2013 stipulated that while mining activities approved under TR -04 could <br />commence, a minimum of an additional five consecutive quarters of water quality monitoring <br />will be required in order to demonstrate baseline hydrologic conditions before mineral extraction <br />may occur. Since approval of TR -04, CBCI has been collecting water quality data in accordance <br />with these requirements for the purpose of establishing baseline hydrologic conditions. CBCI <br />clearly understands that no mineral extraction may commence at the Camp Bird Mine until the <br />Division is satisfied that baseline hydrologic conditions have been established. The fifth <br />consecutive quarter is anticipated to be the first quarter of 2014, at which time CBCI expects to <br />do one of the following: <br />• If CBCI desires to begin mineral extraction, which is beyond the scope of the current <br />approved activities, it will request that that Division make a determination as to whether <br />baseline hydrologic conditions have been established based on the 5 consecutive quarters <br />of water quality data collected at that time. It is at this point in the future, where CBCI <br />