2003-03-11_REVISION - M1977342 (3)

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970-887-4102 SULPHUR RD PAGE @3 "reclamation plan," then it is appropriate to require that the land be returned to its pre-mining condition, thus representiag the natural state of the ecosystem and landscape for the William's Fork area. Section 2.4-Change in Reclamation Plan and Post•rnining Land Use at the Tailings Imporardmentt Conceptual Alrernarive. This section of the amendment would eliminate the present plan fora 100 percent dry cover, and replace it with a plan that would creaze a developed water resource over approximately 70 percent of the impoundment, with the remaining 30 percent continuing under the dry cover scenario. Given that the slopes in the azea west of the tailings impoundment include forested riparian areas, including some Iiydric soils, we concur that it will be the tendency of the site hydrology tb have subsurface and surface flow, especially where these riparian stringers enter the tailing impoundment area, The revegetation plan should consider planting species that are appropriate to moister Sites in these areas. However, based oa surrounding landforms, it is unlikely that open water wetlands were part of the natural system. Given the inherent risks with creating an open water impoundment of this type {discussed below}, it would seem advisable to retain the current plan for reclamation. The tailings impoundment sits above the William's Fork River, midway down the drainage. This scenario has potential implications for National Forest System lands below the impoundment. It appears that a permanent water source would require that the tailings dam be maintained perpetually, and the proposal provides na plan for such maintenance. All dams carry with them the need for maintenance, and the inherent risk of failure. The longer a dam is in place, the greater the dsk of failure. If it were to fail, material and pollutants from the tailings impoundment would be transported to the William's Fork River, thus causing catastrophic damage to the aquatic ecosystem. Effects would not be limited Yo pollutant release, but would also include the physical erosion and sedimentation effects crated by a sudden release of a large quantity of water. Additionally, in drought years such as we are now experiencing, limited inflow of water could leave large areas of the impoundment bed dry, allowing pollutants to become airborne, creating unknown down-wind health and environmental problems. Based on the above discussion items, I respectfully request that the Division of Minerals attd Geology does not approve these sections of the amendment as requested by Climax. Tf you have any further questions about this response, please contact Patricia Hesch, Lands Staff, at (970) 887-4136. Sincerely, f CRAi A. MAG District Ranger cc: Grand County Board of County Commissioners, SO-Lands