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Pinon Ridge Mining LLC <br /> 31161 Highway 90, PO Box 825 <br /> Nucla, Colorado 81424 <br /> April 16, 2019 <br /> Mr. Lucas West, Environmental Protection Specialist <br /> Colorado Division of Reclamation, Mining and Safety <br /> 1313 Sherman Street, Room 215 <br /> Denver, CO 80203 <br /> Transmittal: Technical Revision, Environmental Protection Plan, Sunday Mines Group <br /> Sunday Mine (Permit M-1977-285), Carnation Mine (Permit M-1977-416) <br /> St. Jude Mine (Permit M-1978-039HR), Topaz Mine (Permit M-1980-55HR) <br /> West Sunday Mine (Permit M-1981-021) <br /> Dear Mr. West: <br /> Pinon Ridge Mining LLC (PRM) is submitting the enclosed Technical Revision JR)to the <br /> Sunday Mines Group Environmental Protection Plan (EPP) in response to your letter of <br /> January 23, 2019 regarding Corrective Action at the Sunday Mine. In that letter, you <br /> requested that PRM prepare a TR that addresses stabilization of low-grade uranium and <br /> vanadium stockpiles that exceed 500 parts per million (PPM) uranium at their surface. <br /> In your letter of January 23, 2019, you also state that "500 PPM Uranium, or 0.05% by <br /> mass, is the threshold value whereby a Source Materials permit may be required through <br /> the Hazardous Materials and Waste Management Division with the Colorado Department <br /> of Public Health and Environment"(CDPHE). While that may be true for some materials, <br /> CDPHE does not have regulatory authority over unprocessed mine ore and waste rock <br /> stored at mine sites under the Resource Conservation and Recovery Act (RCRA) Subtitle <br /> C nor its Radiation Program that implements the Atomic Energy Act in Colorado. The laws <br /> and rules for mineral processing are typically much stricter than those applied to mining <br /> operations due to the greater exposure levels that potentially occur during processing. <br /> We believe it is important to make this distinction, as the quoted statement above could <br /> be misinterpreted by the general public and lead to some confusion as to what regulatory <br /> standards apply to the Sunday Mines Group. <br /> However, our company does not dispute the Colorado Division of Reclamation, Mining <br /> and Safety's (DRMS's) regulatory jurisdiction at the Sunday Mines Group and its authority <br /> to interpret its regulations and establish guidelines that the division believes are protective <br /> of human health and the environment. The stabilization measures proposed in the <br /> attached TR are designed to prevent adverse off-site impacts from low-grade stockpiles <br /> during both periods of active operation and temporary cessation. These measures may <br /> include one or more of the following Corrective Actions: <br /> 1. Placement of low-grade ore exceeding 500 PPM uranium on lined ore pads for not <br /> more than 180 days during future mining operations. <br /> 1 <br />