Laserfiche WebLink
Alpine Rock Swan River Resource, M-1993-035 <br />Response to April 16, 2007, DRMS Letter <br />3 August 2007 <br />Page 3 <br />logging procedures, it is believed that the French Gulch site was included <br />amongst those samples. However, it also appears that samples were taken <br />without a procedure in place to permanently record or report these results to the <br />DRMS. <br />As the Division acknowledges, extraction activities at the site have not been of a <br />scale or nature that would typically present substantial water quality issues. The <br />area, however, is replete with pre-regulation mining impacts, including tailings <br />from an abandoned underground mine and mill site directly to the east of the <br />mined area of M-1993-035 and on the same property. No matter what results <br />might be obtained for water quality monitoring at the site, the influence of historic <br />mining conditions is far more likely to affect water quality than the modern <br />recovery of aggregates from dredge piles. <br />Since 1993, Summit County has been actively involved in studying historic <br />mining impacts and facilitating remediation plans. The County purchase of the <br />subject portion of B&B Mines property was, in fact, associated with such study. <br />The underground mine on the site, to the east of the dredge piles, is the subject <br />of a partnership with the federal Environmental Protection Agency (EPA) and a <br />voluntary clean-up plan (VCUP) addressing water quality as well as other <br />environmental issues. <br />Please see the attached letter from current Summit County Planning Director, <br />Jim Curnutte, dated July 6, 2007. It is the County's present position that water <br />testing under the Reclamation Permit will not benefit the VCUP or any other <br />aspect of the County's administration of the property with the EPA. Because the <br />County was the original commentator and has since reversed its position <br />regarding the need for monitoring, this alone is a significant reason to reconsider <br />the water testing program. In addition, the interested parties, including the <br />Division, all agree that the level of disturbance at the site is not likely to cause <br />water quality issues. <br />With this rationale, and based on the analysis and recommendations in the <br />Division's April 16 letter, the operator requests the Division consider a Technical <br />Revision to eliminate water testing from the M-1993-035 permit. <br />3. Soil Amendments. <br />As the Swan River site existed at the time Reclamation Permit M-1993-035 was <br />issued, much of the affected area was covered by gravels and other dredge <br />material. Plant growth medium is in extremely short supply within the boundaries <br />of the affected area, and the Division has acknowledged this condition from the <br />time of the initial review of the permit. <br />The stipulation concerning soil amendments was an accommodation made to <br />encourage innovative approaches to plant growth medium, without requiring <br />