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2015-02-10_PERMIT FILE - M2014045
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2015-02-10_PERMIT FILE - M2014045
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Last modified
8/24/2016 5:57:22 PM
Creation date
2/13/2015 8:15:22 AM
Metadata
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Template:
DRMS Permit Index
Permit No
M2014045
IBM Index Class Name
PERMIT FILE
Doc Date
2/10/2015
Doc Name
Responses to January 15, 2015 Comments
From
Braun Environmental, Inc.
To
DRMS
Email Name
TC1
Media Type
D
Archive
No
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i4 <br />1. INTRODUCTION (6.4.21(1) <br />In a letter dated January 12, 2015, the Division of Reclamation and Mining Safety (DRMS) <br />notified the operator that the Mineral Mountain Gold Project (Permit M2014 -045) was being <br />redefined as a Designated Mining Operation under its interpretation of the Colorado Mined <br />Land Reclamation Act, (CRS § 34 -32 -101), more specifically CRS §34 -32 -105 (a) (3. 5)(1 -11). That <br />order requires implementation of Rule 6.4.21. Neither the operator nor engineer concur with <br />the determination and in fact believe it to be a faulty interpretation of Rule 1.1(14), Rule <br />6.4.21(1) (a), and Rule 7.2.2(1), but the operator has been forced to accept it. Per the order, <br />the purpose of this plan is to meet the requirements of Rule 6.4.21 the template for the <br />Environmental Protection Plan. The document describes how the operator will assure <br />compliance with the provision of the Act and rules to protect all areas that have the <br />"reasonable potential" to be affected by these designated chemicals, toxic or acid - forming <br />materials by constructing an Environmental Protection Plan (EPP). <br />The potential for acid mine drainage (AMD) for the Mineral Mountain Project has been <br />reviewed by Qualified Persons (QP) and it has been found that the project currently does not <br />have the capability of producing acid mine drainage, as the static water level in the Cripple <br />Creek District is well below any anticipated elevations that are reasonably anticipated to be <br />reached on the project. Testing of the exposed rock forming units, and a review of physical site <br />conditions, both locally and district -wide, show that there is no acid generating rock accessible <br />at this time, and based on the information available, there is little to no chance of the <br />production of acid - generating rock in the near future. The project is not using "designated <br />chemicals ", as defined in Rule 1.1(13) of the DRMS regulations, and does not anticipate using <br />them, so no plan is currently necessary for managing such chemicals. A review of the site finds <br />that there are no heap leach pads, land application sites, insitu operations, or uranium mining <br />or processing associated with the permit. Thus, based on the Act and DRMS regulations, the <br />reason for producing an Environmental Protection Plan does not exist and as a result, there are <br />no specific areas that have potential to produce any environmental hazards. However, to meet <br />the order, the plan is as follows. <br />1 <br />
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