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2021-04-15_REVISION - M2014045
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2021-04-15_REVISION - M2014045
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Entry Properties
Last modified
1/19/2025 5:52:37 AM
Creation date
4/27/2021 5:05:46 PM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M2014045
IBM Index Class Name
Revision
Doc Date
4/15/2021
Doc Name
Application
From
Braun Environmental
To
DRMS
Type & Sequence
AM1
Email Name
ERR
JDM
Media Type
D
Archive
No
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EXHIBIT C <br /> AMENDMENT TO MINING PLAN <br /> Introduction <br /> On June 2, 2020, Division of Reclamation and Mining Safety (DRMS) personnel performed a <br /> site inspection, and conducted a follow-up on July 15, 2020. On August 19, 2020, the Colorado <br /> Mined Land Reclamation Board (CMLRB) found the Operation in violation of C.R.S. 34-32-124 <br /> for failure to comply with a permit. The Board ordered that the Operator file a Technical <br /> Revision within fifteen days of mailing of the Order to propose a plan to appropriately dispose of <br /> xanthate and flotation concentrate currently stored on site, and to either excavate and haul <br /> uncharacterized mill tailings off-site to an appropriate disposal, or have a third party sample and <br /> characterize the mill tailings to determine if they can be left in place. The Order also required <br /> that Operator file an Amendment Application updating the Mine Plan and Environmental <br /> Protection Plan to describe current and proposed mining and milling activities at the site. The <br /> operator immediately contacted professionals to perform site investigations and to test the <br /> materials that had been identified by DRMS personnel. <br /> As had already been determined prior to issuance of the 2015 permit, the Board required testing <br /> found that the regulated metallic elements remaining in that tailings sand met all normal U.S. <br /> Environmental Protection Agency (EPA) and Colorado Department of Public Health and <br /> Environment (CDPHE) standards for that locale. Additionally, it was found that in spite of its <br /> scary sounding name, xanthate is a simple organic compound, made of common elements from <br /> the first three rows of the periodic table, and in fact consists of the very same elements that make <br /> up proteins in the human body. It, and its family of chemicals, have been used for processing <br /> minerals in Colorado for the last 100 years, with no evidence that any significant negative issues <br /> have ever occurred when it is used as recommended by the manufacturers and distributors. <br /> Neither the EPA nor the CDPHE consider xanthate to be a hazardous substance or hazardous to <br /> the environment, and as a result have never developed any standard tests to detect its presence or <br /> to quantify it. Per the orders of the CMLRB, a test was specifically developed for this site, and <br /> as would be expected, based on the chemical characteristics of the compound, no detectable <br /> concentrations were found in the tailings sand, in the concentrates, or in the residue remaining <br /> from the evaporated process water. It is well known that this compound is used in mining at <br /> low concentrations and that it degrades rapidly in the environment. The investigation concluded <br /> that the sand tailings met EPA and CDPHE environmental standards, thus posed no hazard to <br /> human health of the environment. Since the material is non-hazardous and if the operator <br /> wishes, it can be disposed of as any other solid waste at a licensed Subtitle D landfill. The <br /> investigation then concluded that since the sand tailings meet regulatory standards, the best and <br /> most environmentally friendly option will be to leave them in place on the site, as was being <br /> done in 2020, and as specified in the Tailings Disposal Plan that has already been submitted. <br /> As indicated in Section (1)(a) of the original Mine Plan, the operation is still in prospecting and <br /> 2 <br />
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