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05i10i00 14:49 LRND & WRTER FUND OF THE ROCKIES ~ 3038328106 N0.853 D06 <br />standards for conrA**+;nA~ts that may be released in the long and short term from the VLF during <br />and after the active mining and leaching. <br />Accurate analysis and performance/reclamation assurances are required by the Mined Land Act <br />and Rule 6.4.20, For example, Rules 6.4.20(5) and (6) require n complete analysis of all <br />Designated Chemicals such as cyanide and its byproducts, as well as a12 toxic-forming materials. <br />See also, Rules ti.4.20(12)(Monitoring); (14)(Geochemical). T'he failure to protect against <br />adverse releases from the spent ore, especially after the liner system is punctured and water flows <br />freely from the VLF into the Arequa Gulch system, fatally flaws the Application.Z This error is <br />in addition to the mare basic failtlte to analyze and properly monitor the potential for releases <br />other than WAD CN. <br />The fact that CC&V may someday hold an NPDES/CDPS permit far the VLF releases after liner <br />breaching does not exempt CC.~V from the requircment in this Application to fully analyze, <br />monitor, protect agaihst, sad bond, for other than WAD CN releases. Regarding the financial <br />asstuance calculations, CC&V admits that the calculation was limited to only WAD CN levels. <br />As noted above, basing the reclamation/detoxifuation financial assurance amounts on such a <br />limited parameter field violates the fundamental requirement that such costs represent the full <br />liability that rosy accrete to the state and people of Colorado. <br />C. The Leached Ore Should Not Be Placed in the Open Envirotunent <br />CC&V proposes to dispose of the off-loaded lgached ore either in the waste rock/overbutden <br />dumps or a9 road construction materials. Similar to the problems associated with puncturing the <br />VLF liners upon closure, disposal in the open environment, with only a check for WAD CN, <br />does not adequately protect the public and comply with the Mined Lend Act and MLRB Rules. <br />D. The Lack of SeQreeation and Other Controls to Minimize the Potential for AMDffoxics <br />Violates the Mined Land Act, MLRB Rules, and CC&V's Previous Commitments <br />CC&V again relies on the seepage to the Carltott/Roosevelt Tunnel rystems in its attempt to <br />eliminate its previously-agreed upon commitments to segregate higher-sulfur waste rock and <br />protect against the resulting AMD potential. CC&V has never, and can never, prove that <br />absolutely no water contacting the waste rock dumps could ever reach surface wazers in Arequa <br />Gulch. The plan to now deposit high-sulfur waste rock directly in Arequa and Squaw Gulches, <br />with only permeable material placed on the top (but not all sides) of the dump directly violates <br />the Act's requirement that "acid-forming or toxic-producing material that has been mined shall <br />be handled in a manner that will protect the drainage system from pollution." CRS 34-32- <br />~ On a more fundamental level, the VLF liners should not be punctured at all. Rather, the <br />DMG/MLRB should require that the liner system remain intact upon cessarion of leaching and <br />complete detoxification of all pollutants, dewatered, and then capped with an impermeable cap or <br />other mechanism to prevent any infiltration of water into the heap. <br />5 <br />