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<br />Mr. Bruce Humphries <br />December 28, 1994 <br />Page 4 <br /> <br />In compliance with 31-32-116(q) of the Colorado Mined Land <br />Reclamation Act, Umetco and EFNI have carried out reclamation <br />activities with reasonable diligence concurrent with mining <br />operations to effectively control erosion and protect the: drainage <br />system from water pollution. Subsequent to field concurrence from <br />Mr. 3ames Dillie during his November, 1993 mine inspection, Umetco, <br />followed by EFNI, has performed reclamation activities in all waste <br />rock areas to prevent stormwater runon to these areas and to <br />eliminate the possibility of either erosion or runoff of <br />potentially contaminated stormwater. During the 1993 inspection, <br />Umetco personnel were told that these stormwater management <br />practices would be acceptable; however, no mine inspection report <br />was issued. <br />The Colorado Department of Health (CDH) issued a Final <br />stormwater Permit for the Sunday Mine (Permit Number COR-040107), <br />under the Colorado Discharge Permit System (CDPS). :Following <br />issuance of the permit, Umetco submitted a stormwater Management <br />Plan, which includes the Best Management Practices (BMP) which had <br />been discussed in the field during the 1993 mine inspection. A <br />copy of the stormwater Management Plan for the Sunday Mine is <br />included as Attachment 1. The stormwater Management Plan includes <br />a copy of the CDPS permit for the Sunday and other mines ~~nd a map <br />of the Sunday property. The BMP's have been implemented,. and are <br />effective in preventing any stormwater transport of F~otential <br />contaminants from the waste rock areas. The permit requires that <br />annual inspections assessing the adequacy of the BMP's be reported <br />to the CDH. <br />Summary <br />In summary, EFNI believes that the Sunday Mine does not meet <br />the criteria established for a DMO in Rule 1 for the following <br />reasons: <br />(1) No designated chemicals used in metallurgical processing <br />are present on-site; <br />(2) The waste rock which exists on site poses no threat to <br />human health, property, or the environment; <br />(3) The host rock is non-acid-generating, and groundwater <br />levels preclude the possibility of any mine drainage; and <br />