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A9E~LI0 [o Greg Walcher <br />1 ~4larch 16, 2000~Response to AI[tance (or Responsible [Yfining <br />Page 2 <br />Response to Item 2 <br />Our understanding of EPA's Toxic Release Inventory (TRI) is that it does not give a <br />realistic estimate of the potential for impacts to human health or the environment. For <br />example, for toxics to have impact, there must be a pathway for the substance to get <br />from the place of origin to the target. In the case of mining, most of the inventoried <br />toxics are either locked in the mineral matrix and/or are so isolated that there is no <br />reasonable or likely potential for detrimental impacts to human health or the <br />environment. <br />Secondly, regulated mining operations are required to meet state and federal <br />standards for all releases to the environment. If they violate standards, they are <br />subject to various combinations of civil and criminal penalties. If mining operators are <br />permitted to release toxic substances to the environment, provided that permit <br />standards are not violated, then we fail to see the significance of the Toxic Release <br />Inventory. <br />Response to Item 4: <br />The Alliance seems to be concerned that if the Cripgle Creek and Victor Gold Mining <br />Company's (CC&V) proposed permit modification is approved, the mine may be in <br />operation for decades. The operation has had a history of compliance with its MLRB <br />permit. The site is monitored monthly by DMG. So, as long as there are adequate <br />regulatory programs to monitor site activities and an adequate reclamation bond is in <br />place, the risk is low. For example, we know of no instances in the Unlted States of <br />death or injury to private citizens due to these types of mining operations. This does <br />not mean that this Division takes proposed changes in CC&V's operation lightly. Each <br />permit application or modification to the existing permit receives intense scrutiny and <br />review before it is approved. <br />cc: Ron Cattany <br />m: \ oss \ gaw \ al liance <br />