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F,om: Je!!9¢rman Far. +1303)546-9922 To~ Beman KeRelew Fa.. (303i932~B106 Pagc 4 0! 9 Tues~y. May 09. ?0001.13 PM <br />{olorodo Wild pow q <br />their gold content, yet no details of that content is given. As noted by CCV, these materials may <br />weigh between 600.000 and 800.000 tons. Sttclt a large volume of materials must be full}' <br />accounted for. <br />With backfilling also a part of the plats. Amendment R does not ensure that MLRB Rules will be <br />met. For example, Rule 3.1.5(2) states: <br />When backfilling is part oC the plan, the Oprrator shall replax overhurden and waste materials in <br />the mined area and shall ensure adequate compaction for stability and to prevent leaching of <br />toxic or acid-forming materials. <br />Apparently some of the mine pits wilt he backfilled but backfilled materials may leach acid- <br />forming materials. This would not compl}• tcith the Rule. ,also, backfill should be done to <br />product controlled drainage to surface water trcauucnt facilities, rather than uncontrolled <br />leaching to subsurface tunnels and other release conduits. Reliance on the Cazlton Tunnel to <br />supposedly neutralize leachate from backfilled pits does not comply with Rule 3.1.5(2). The <br />Rule specifically prevents any backfilled tttaterial Y~ont "leaching ... acid-forming materials." <br />This is a very strict standard, arguably much more difficult to meet than the general requiremetri <br />that the Icachatc meet all water quality requirements. <br />ENVIRONMENTAL PROTECTION <br />Colorado Wild believes that the failury to submit an adequate ettvironntental protection plan <br />(EPP) and to meet performance and reclantatipn standards of the Mined Land Act is an issue <br />which must be satisfactorily addressed before tlte. Antendtnent Application can proceed. <br />Colorado Wild has identified the following areas as representing the Application's most <br />significant problems. <br />1. The DMGJMLRB Cannot Approve the Spent Ore Detoxification/Rinsing Facilities Until <br />Detailed Facility Plans Are Submitted b}' CCV <br />One of the critical new issues arising with the submittal of Amendment 8 is CCV's <br />acknowledgement that the anticipated ore production exceeds the capacity of the Valley Leach <br />Facility (VLF), even at full build-out of the VLF. According to the company: <br />The overall capacity of the VLF with the Pltase IV azea and a maximum depth of approximately <br />590 feet will be about 262 million tons. This is abou130-50 million tons short of the expected <br />ore production. In order to provide the capacity reyuired for beneficiating the additional ore. <br />CC&V anticipates unloading previously leached ore for rinsing to a lined area(s). <br />Amend. R, Vol. i, PrnjeM Description at p. 75. The company then states that: <br />The location and design of the rinse area(s) have not been dytermined. but will be submitted to <br />the OMLR for review and approval prior to cottstntction.... CC& V recognizes that additional <br />design details are nycessazy before allowing unloading of ory from thy VLF. However. as part of <br />this Amendment it is requested the O1vII.R/MLRB approve the concept of unloading the VLF to <br />