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2.3 Permit History <br /> On April 16, 1990, the DRMS (then the "Colorado Mined Land Reclamation Division") <br /> deemed Central City Consolidated Mining Company's ("CCCM" or"Operator") <br /> application for a Mining& Reclamation Permit complete. The Bates-Hunter Mine and <br /> the Golden Gilpin Mill were the principle features included in this application. The <br /> permit was approved and issued on July 13, 1990. In this permit,the reclamation plan for <br /> the structures stated that they were to remain post-reclamation. <br /> "8. Structures to Remain Ater Reclamation <br /> All existing structures will remain after reclamation All trash, scrap equipment, ore <br /> stockpiles and other non-essential items will be removed All areas will be graded to the <br /> reclamation contours in committed to in Part 2 of this Reclamation Section." ("Bates- <br /> Hunter Permit Application", pg. 8 of Exhibit D of the original document) <br /> On April 16, 1990, the DRMS issued a Memorandum to the Gilpin County Planning <br /> Department informing them of the CCCM permit application and stating "The applicant <br /> proposes to reclaim the site for industrial and commercial use". The permit file includes <br /> no statement provided by Gilpin County in opposition to the application. <br /> The original financial warranty, set by the Mined Land Reclamation Board, for the <br /> operation was $5,000, the maximum financial warranty for a Limited Impact 110(2) <br /> permit at that time (5/26/1990). <br /> The financial warranty adequacy was reevaluated by the DRMS (then the "Colorado <br /> Mined Land Reclamation Division") on 5/19/1993 and determined to be $3,108, less than <br /> the bond provided by CCCM. Notes supporting this reevaluation state "all structures <br /> remain" (4/30/1993) appear in the permit file. <br /> On January 25, 1994, CCCM requested an amendment [technical revision, TRl] to the <br /> permit to construct a water treatment plant at the Bates-Hunter mine site. Approval was <br /> granted by the DRMS for the technical revision on March 7, 1994. No increase in the <br /> financial warranty was mentioned. No provision requiring the removal of the water <br /> treatment plant was included in the permit file. <br /> A DRMS inspection report from an inspection on July 7, 2004 stated: "...the Division <br /> will calculate a current reclamation cost estimate and forward the estimate to the <br /> operator as soon as it becomes available". Following that inspection, on September 24, <br /> 2004, the DRMS inspected the permit sites, again. The inspection report for that date <br /> includes an itemized inventory of mill reagents, petroleum products and chemicals and <br /> states: "The Division will apply an itemized reclamation cost for disposal of the reagents <br /> and/or chemicals to a local landfill." No further discussion of the financial warranty is <br /> included in the permit file until 2010. <br /> The Colorado Department of Public Health and Environment ("CDPHE") and the United <br /> States Environmental Protection Agency("EPA") completed a remediation project <br /> Bates-Hunter Technical Revision(TR-03) Page 4 of 380 <br />