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~ III IIIIIIIIIIIII III ~ <br />Mine Development, Inc. <br />16360 Park Ten Place #325 <br />Houston TX 77084 <br />(713)578-1440 Fax: (713)578-3159 <br />March 21, 1996 <br />Received <br />Mr. Steve Shuey pENVER U~r L . , , <br />Division of Minerals and Geology p~F~CiE <br />Durango Field Office t)urar~go F,ea Otr~ca <br />1474 Main Avenue, Room 207 iDlrlabn of Miners 3 Geo <br />Durango, CO 81301 b9Y <br />RE: Neglected Mine, Permit No. M-81-165, Conversion No. 1 Adequacy Review No. 3 <br />Dear Mr. Shuey, <br />Below are Mine Development, Inc.'s (MDI) responses to the Divisions latest adequacy <br />review. MDI has elected to follow the convention established in previous responses. <br />Exhibit C <br />1. MDI has committed to sample the footprint of the ore stockpile areas, at the <br />time of reclamation, to determine if toxic accumulations of manganese, silver, <br />aluminum and mercury are present in the soil which may hamper successful <br />revegetation efforts. If the footprint is found to exhibit toxic conditions, MDI has <br />committed to excavate 6-8 inches of material and replace it with clean topsoil <br />before seeding. <br />Please revise this commitment to indicate that all material in the footprint of the <br />stockpiles, proven to exhibit toxic conditions due to high metal accumulations <br />caused by prolonged stockpile of ore on the site, will be removed, disposed of <br />and replaced by clean topsoil. A depth restriction on this commitment is not <br />acceptable. Additionally, please indicate how the contaminated material will be <br />disposed of. <br />To revise our earlier commitment, MDI will remove, dispose of and replace with clean <br />topsoil, all material in the footprint found to exhibit toxic conditions due to high metal <br />accumulations. Additionally, MDI understands that there shall be no depth restriction <br />with respect to this commitment. When and if MDI is required to uphold this <br />commitment, MDI would like, at the time of reclamation, to study the various <br />alternatives available for disposal of toxic material. These alternatives might include <br />but are not limited to in-situ remediation, incineration, solidification and encapsulation <br />or disposal off site in a hazardous waste landfill. MDI asks that the Division understand <br />the reason for this request, which is, as technology improves certain disposal <br />alternatives become feasible. <br />