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On October 11, 2013, CCCM refuted to the DRMS recalculation, stating that the DRMS <br /> label of"scrap" and"unused equipment"was not considered by CCCM to be "scrap", but <br /> replied that "...it's not actually scrap, it is equipment used to operate the mine...The <br /> scrap and refuge [sic]that the inspectors look at is our store for replacement parts". <br /> The DRMS provided notice of outstanding corrective actions to CCCM on November 13, <br /> 2013. None of these corrective actions included an increase in the financial warranty. <br /> On December 13, 2013, the DRMS notified CCCM of a possible violation for items, <br /> including failure to increase the financial warranty by the amount of$10,500.00. No <br /> discussion was recorded regarding CCCM's refutation of the DRMS recalculation. <br /> On January 9, 2014, the DRMS conducted another inspection of the permit site. The <br /> DRMS restated its position that"The increase of the financial warranty was due to an <br /> excessive amount of old equipment and refuse scattered throughout the site". No <br /> discussion, dialogue or correspondence with CCCM is provided in the permit record. No <br /> mention of the removal of any structures was included in either SI-1 or SI-2 financial <br /> warranty recalculations. The DRMS did state that"The Operator was in the process of <br /> removing refuse and old equipment from the mill yard during the inspection. A <br /> substantial portion of the refuse which the Division observed during the August 2013 <br /> inspection has been removed from the property. As noted above, the financial warranty <br /> increase was primarily associated with the cost to haul and dispose of the old equipment <br /> and refuse. The Operator has informed the Division that the clean up[sic]of the mill <br /> yard will continue. Therefore, the Division will re-evaluate the required financial <br /> warranty amount once all of the material has been removed." <br /> On March 31, 2016, CCCM was notified of the Temporary Cessation(TC-1) expired on <br /> March 8, 2016. <br /> The DRMS inspected the permitted site on April 26, 2016. The inspection report states <br /> that"The current financial warranty amount of$5,000.00 is not adequate to complete <br /> reclamation. The Division will perform a full financial warranty calculation which will <br /> take into account the reclamation of all surface disturbances. In addition, the financial <br /> warranty calculation will address the removal of any structures which are not authorized <br /> to remain in the approved Reclamation Plan." <br /> On May 27, 2016, the DRMS conducted another inspection of the permitted site(s). The <br /> inspection report states that"The inspection was conducted to ensure the financial <br /> warranty is adequate to cover the current cost of fulfilling the Reclamation Plan as <br /> required by Hard Rock Rule 4.2.1(1) ... Based on observations made during the <br /> inspection, $5,000.00 is no longer adequate to complete reclamation of the site. The <br /> Division will perform a complete bond calculation to ensure the financial warranty <br /> amount is adequate to complete reclamation. Notice of any increase to the financial <br /> warranty will be sent under separate cover... Both the Bates-Hunter Mine and the <br /> Golden Gilpin Mill contain refuse, scrap metal, and mining equipment in various states <br /> Bates-Hunter Technical Revision(TR-03) Page 6 of 380 <br />