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05i10i00 14:49 LPND 8 WATER FUND OF THE ROCKIES ; 303839106 N0.853 D03 Mined Land Act, requires the submission of a complete EPP for a Designated Mining Operation (DMO) such as the CC&V operation. CC&V violates Rule 6.4.20's requirements for detailed facility, materials handling, geochemical, water quality, reclamation, environmental protection, end other analysis and performance assurances. Rule 7 requires that all of the requirements in Rule 6 for Designated Mining Operations must be met before the DMG/MI.RB can approve the Amendment. The following are some of the Application's most significant errors. A. The DMG/MLRB Cannot Approve the Spent Ore Detoxification/RinsingFncilities Until Detailed Facility Plans Are Submitted by CC&V One of the critical new issues arising with the submittal of Amendment 8 is CC&V's acknowledgement that the anticipated ore production exceeds the capacity of the Valley Leach Facility (VLF}, even at full build-out of the VLF. According to the company: The overall capacity of the VLF with the Phase N area end a maximum depth of approximately 590 feet will be about 262 million tons. This is about 30-50 million tons short of the expected ore production. >n order to provide the capacity required for beneficiating the additional ore, CC&V anticipatcs unloading previously leached ore for rinsing to a lined aeea(s}, t Amend. 8, Vol. I, Project Description at p. 75. The company then admits that: The location and design of the rinse area(s) have not been determined, but will be submitted to the OMLR for review and approval prior to construction.... CC&V recognizes that additional design details are accessary before allowing unloading of ore tom the VLF. However, as part of this Amendment it is requested the OMLR/MI.RB approve the concept of unloading the VLF to lined area(s) recogttiang that additional details in the form of a technical revision will be submitted far final approval. Id (emphasis added). The company does not even know how many of these detoxification facilities it will need at the site, noting only that there may be more than one. Apparently, CC&V feels that a future technical revision process fully substitutes for the requirement that this Amendment comply with MLRB Rules and the Mined Lead Act. That is not the law. The post-Summitville revisions to the ML.RB Rules specifically require that application amendments conrain detailed plans for any facility that may handle Designated Chemicals such as cyanide. These facilities aze known as Environmental Protection Facilities (EPFs). The one or more "lined rinsing area(s)" noted above aze cleazly EPFs. ~ Based on infomoation provided in Amendment 7, the previous maximum height for the VLF was 504 feet. Now, due to the need for increased capacity, CC&V claims that the VLF can withstand heights of 590 feet. CC&V has not adequately explained how it has changed operations to the extent that the additiona186 feet is now acceptable, For example, it is not proven that the exaa height and weight of the added material, as well as volume of the added leachate, does not have the potential for degradation to the integrity of the liner.