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the approved post-mining land use for all of the American Tunnel area. Dresser Minerals has expressed <br />no land use plans to the Division. GKMC has proposed to succeed to the property and continue <br />conducting water treatment there. San Juan Corp has indicated it intends to continue using the Quonset <br />but beside the sediment ponds -which would be an industrial land use -but they opposed SGC's eazlier <br />attempt to change the land use of other parts of the site to industrial. Thus, in light of the approved post- <br />mining land use, we are curious about SGC's intentions for reclaiming these properties. <br />SGC's reclamation plan calls for removal of the water treatment facilities {including the lime dosing <br />system and sediment ponds), removal of mine buildings and structures, and surface reclamation, all of <br />which aze consistent with the post-mining land use of rangeland. Considering the following site <br />conditions, the Division has questions regarding how SGC may complete this reclamation. <br />1. The American Tunnel water treatment facilities are integral to the CDPS discharge from the <br />American Tunnel area. However, SGC is obligated under the reclamation plan to remove these <br />water treatment facilities. In order to leave these facilities in place, the post-mining land use must <br />be changed to one that is compatible with leaving these facilities in place. This obligation can be <br />revised if the situation so required, and provided landowners and land managers are consulted, and <br />that local land use authorities approve. <br />2. GKMC has taken over treatment of the American Tunnel dischazge and is simultaneously <br />responsible for treating the dischazge from the Gold King #7 portal. We aze aware of no limit to <br />GKMC's obligations under the CDPS permit. There is no end in sight for the treatment facility, <br />and hence no way for SGC to complete its reclamation obligations without revising or amending <br />the reclamation permit as it regazds the water treatment facilities. <br />3. SGC conveyed to San Juan Corp the sediment ponds area, leaving SGC's access for water <br />treatment and site reclamation in question. <br />4. GKMC's lease on the sediment ponds, which are now owned by San Juan Corp, is due to expire <br />shortly, according to Steve Fearn. Provisions for reconfiguring the water treatment system to <br />accommodate reclamation of the sediment ponds, which aze integral to the current water treatment <br />system, aze not evident. SGC cannot simultaneously reclaim the ponds and allow GKMC to <br />continue treatment operations. <br />5. GKMC is currently under violation notices issued by the Mined Land Reclamation Boazd and the <br />Colorado Department of Public Health and Environment. This condition precludes GKMC from <br />obtaining a permit for the American Tunnel area until such violations are cured. <br />6. Plugging the American Tunnel may have caused flow from the Gold King portal to increase, or it <br />may have caused water quality there to degrade. If so, SGC may have obligations under the DMG <br />permit to further minimize impacts to the hydrologic balance. <br />With this letter, the Division asks SGC to cleaz up questions about the American Tunnel azea. <br />I. Competing desires for post-mining land uses. Please explain how SGC intends to resolve the <br />post-mining land use issue. What are your plans for the building that sits -apparently - on lands <br />owned partly by Dresser and GKMC, knowing that GKMC has expressed at least a desire to <br />continue occupying that part of the building on its property? With the possible exception of the <br />mine portal, none of the structures or parts thereof can remain unless the post-mining land use is <br />changed appropriately. The Division can still consider a request for change inpost-mining land <br />use for this azea, if SGC desires. <br />2 <br />