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the high concentration of heavy metals and acidity associated with waste materials); and (6) what <br />aze the negative effects, on and off site, in the event of a breach, leaching scenario to sub-surface <br />water, above ground water resources, vegetation, wildlife, aquatic life and fisheries? <br />Essentially, under amendment four (4) the Company is asking the State of Colorado and <br />Grand County to accept a scenario that, as presented, has no supporting data or case studies that <br />prove it is a feasible proposal. Further, they request a conditional approval of this generalized <br />scenario be granted and later submit a technical revision that covers engineering design and <br />information necessary to evaluate this alternative and determine the relevant changes in the <br />financial warranty for the facility. A "Technical Revision" is a change in the permit, which does <br />not have more than a minor effect upon the approved Reclamation Plan. This alternative is cleazly <br />an amendment to the Reclamation Plan, not a Technical Revision, because it will have a major <br />effect to the Reclamation Plan and it should not be considered until a detailed feasibility study <br />which addresses the water quality, structural, operational and financial issues which may arise <br />because of this scenario. In addition, a pilot study is recommended to verify the results of the <br />Company's analysis. It is imperative that a proper evaluative analysis is conducted. For example, <br />important information to consider under this alternative is the current structural integrity of the <br />tailings pond dam. This is brought to your attention because, in the past, the Company has <br />implemented bypasses around this facility due to concerns of dam breach and leaching problems. <br />Said water impoundment, dam, inlet and spillway would be required to meet the regulatory <br />requirements as each relates to permitting, design and engineering, safety, breach and water rights <br />under this alternative. Lastly, the proposed "wet cover" scenario will require that the Company <br />obtain a 1041 Permit for a Industrial Water Project, pursuant to Article 5 of the Grand County <br />Administrative Regulations for Areas and Activities Designated as Matters of State Interest. <br />Grand County does not accept or support this proposed amendment. <br />The Company has agreed to process the proposed Revision of 100 Percent <br />IDry Cover Reclamation to 70 Percent Water Resource Reclamation as a <br />Permit Amendment and not a Technical Revision (see Paragraph No. 1 of <br />Exhibit "A"). At the time the "wet cover" Amendment is to be considered the <br />Company will provide a feasibility study, which addresses the water quality, <br />structural, operational and financial issues, design and engineering, a geo- <br />technical analysis and other support documentation. In addition, this wet <br />cover scenario includes a water treatment system that will require a 1041 <br />Permit to be issued by Grand County. There is no guarantee that a 1041 <br />Permit will be issued, as it is a public hearing process with comprehensive <br />engineering and technical data required before review. <br />It has come to our attemion during review of AM-04, that the Company has also under <br />review what is known as TR-12. In TR-12, the Company plans to utilize an existing .17 acre <br />landfill and develop a new 7.5 acre landfill at the Mill site for deposition of materials associated <br />with operation (i.e., buildings). The landfills, both existing and proposed aze not adhering to State <br />or County regulations. It is our understanding that the Department of Public Health and <br />Page 5 of 9 <br />