2019-01-04_REVISION - M1994117 (3)

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CMC Response: On July 26, 1995, the Colorado Mined Land Reclamation Board approved Colina Oro Molina's application for a permit for the Gold Hill Mill. This permit's Reclamation Plan essentially followed the original Reclamation Plan filed by the Gold Hill Ventures Limited Partnership on July 20, 1985, which was approved by the Mined land Reclamation Board on September 26, 1985, under the Cash Mine Permit No. M-1983-141. The sole purpose of Colina Oro Molina's Reclamation Plan was to close the Gold Hill Mill and cease further milling operations at this site. Various Reclamation Plan Maps were filed by Colina Oro Molina's representatives and consultants during the time between when they applied for a Reclamation Permit on December 12, 1994, and when it was finally approved on July 26, 1995. None of the documents that were filed by Colina Oro Molina altered the approved Reclamation Plan filed on July 20, 1985. On June 16, 1998, ITEC Environmental became the successor operator to Colina Oro Molina of the Gold Hill Mill Permit No. M-1994-117. Although ITEC Environmental altered the permit boundaries and enlarged and rebuilt the tailings pond, this permitted operator did not revise the original Reclamation Plan filed by the Gold Hill Ventures Limited Partnership on July 20, 1985. Therefore, the pertinent documents may be found under the original Reclamation Plan filed with the Amendment to the Cash Mine Permit No. M-1983-141 on July 20, 1985. 24) The operator provided a revised reclamation cost estimate that removes language regarding an incremental acreage increase and adds costs for decommissioning the Times Mine water pipeline. However, the estimate does not provide enough details for the Division to calculate the actual costs to reclaim the site based on what it would cost the State of Colorado using an independent contractor to complete reclamation, as required by Rule 6.3.4(2). Please provide more details for the tasks listed in the estimate, including specific structures to be removed, and material volumes, dimensions, lengths, etc. Additionally, please provide an estimated distance to the site at which demolished/removed materials will be disposed. CMC Response: The only structures that would be removed are the Gold Hill Mill Waterline and the Pump Station. The elimination of the formerly proposed (and subsequently withdrawn) footbridge across Left Hand Creek eliminates some of the time and effort to reclaim the Left Hand Creek Pump Station, but CMC is not reducing the cost estimate because of this decision. The specific structures that would be removed at the Left Hand Creek Pump station would still include the 8 by 10 foot metal conex. The maximum size of the fuel tank that would be inside a containment sump would also be 8 x 10 feet. This would require a Fork Lift and a Flat Bed/Trailer and an operator for this equipment. Two laborers would be needed to assist the Fork Lift and Flat Bed/Trailer operator/driver. This should not require more than one full day to complete this work based on previous experience of the Applicant. However, the maximum time that might be required by an independent contractor could be two full days. The Gold Hill Mill Pipeline will still require two workers cutting the two (2) inch HDPE pipeline into manageable lengths of approximately ten (10) foot lengths and hauling these pipe sections down hill to the nearest of the four historic mine access roads that come in from Lickskillet Road to the Waterline. CMC has estimated that it will take 2 laborers working 8 hours a day for 5 days to complete the removal of the pipeline based on previous experience. A contractor might need seven days to complete this task. If the lower 1,500 to 2,000 feet of the pipeline is installed using two (2) inch galvanized steel pipe in twenty-one foot lengths, the cost of removing the Pipeline 12