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March 18,2022 <br /> Page 7 <br /> definition of acid—or toxic—producing materials in Rule 1.1(1) relates solely to materials which <br /> contain detrimental amounts of chemical constituents such as acids, bases, or metallic <br /> compounds. There is no evidence that any such material exists at the Cross Mine that meets this <br /> definition. <br /> Based on the well-documented surveys and analytical reports pertaining the geology and ore <br /> deposits specific to the Grand Island District, of which the Cross Mine is a part, there is no <br /> evidence of the development of acid mine drainage from workings, host rock, or waste rock at the <br /> Cross Mine. See Affidavit of Sean Muller, 3; see also, Core Laboratories and USGS reports <br /> referenced below. <br /> In support of GIR's AM 2, GIR provided the Division with various environmental reports and <br /> studies performed related to the Cross Mine property, including an acid-base accounting that was <br /> performed in 1994 and 1995. For ease of reference, GIR is submitting herewith a copy of the <br /> reports referenced below in Appendix A, which contain information in support of GIR's appeal. <br /> The discussion above comparing the Cross Mine operation against the criteria for DMO <br /> designation indicates that the Cross Mine should not be designated as a DMO, but should instead <br /> maintain its 1 10(2) permit status. <br /> Pursuant to Rule 7.2.4, GIR disputes the Division's pending designation of Cross Mine as a DMO. <br /> We request that the Division reverse its pending designation as we have demonstrated there is an <br /> insufficient factual basis for designating the Cross Mine as a DMO. <br /> Dated: March 18, 2022 /sl Robert E. Botts, Jr. <br /> Robert E. Botts, Jr., #21317 <br /> Zane Gilmer, #41602 <br /> STINSON LLP <br /> 1144 Fifteenth Street, Suite 2400 <br /> Denver, CO 80202 <br /> Telephone: 303.500.7190 <br /> robert.botts(c-i)stinson.com <br /> zane. ig ImerLstinson.com <br />