2003-03-11_REVISION - M1977342 (2)

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970-887-4102 SULPHUR RD PAGE 03 "reclamation plan," then it is appropriate to require that the land be returned co its pre-mining condition, thus representing the natural state of the ecosystem and landscape for the William's Fork area. Section 2.4-Change in Reclamation Pdan and Post-mining Land Use at the Tailings Impoundment; Conceptual Alternative. This section of the amendment would eliminate the present plan fora 100 percent dry cover, and replace it with a plan that would create 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 area west of the tailings impoundment include forested riparian areas, including some Iiydric sails, we concur that it will be the tendency of the site hydrology to have subsurface and surface flow, especially where these riparian stringers enter the tailing impoundment area The revegetation plan should consider planting species chat are appropriaze to moister sites in these areas. However, based on surrounding landfotnns, 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 cuaent plan for reclamation. The tailings impoundment sits above the William's Fork River, mid-way down the drainage, This scenario has potential implications for National Forest System lands below the impoundment. It appears that a permanent watec source would require that the tailings dam be maintained perpetually, and the proposal provides no plan for such maintenance. All darns carry with them the need for maintenance, and the inherent risk of failure. The longer a dam is in place, the greater the risk 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 ro the aquatic ecosystem. Effects would not be limited to pollutant release, but would also include the physical erosion and sedimentation effects created by a sudden release of a large quantity of water. Additionai[y, in drought years such as we are now experiencing, Iimited 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 and Geology does not approve these sections of the amendment as requested by Climax. If you have any further questions about this response, please contact Patricia Hesch, Lands Staff, az (970) 887-4136. Sincerely, (~G~r~~/~i~~~ v,~ CRAIG'A. MAGV~JII~ District Ranger cc: Grand County l3oard of County Commissioners, SQ-Lands