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<br />Mr. Bruce Humphries <br />December 28, 1994 <br />Page 3 <br />compounds". we are unaware of any material on site that <br />meets this definition. <br />(c) No acid mine drainage, as defined in Rule 1, occurs or <br />has the potential to occur due to mining or reclamation <br />activities. As stated above, the host rock is primarily <br />non-acid-forming sandstones of the Salt Wash member of <br />the Morrison formation. Based on the discussions we have <br />had with field operations, minor seepage of water is <br />first encountered at approximately the 500-foot level, <br />and no F~umpinq is required to keep the mine dry. No <br />water drains Prom the mine. <br />(d) The board should exempt the Weat Sunday Mina operation <br />Prom designations as defined in Section 34-32-112.5, <br />because as set forth in subsection (2), toxic or acidic <br />chemicals are not stored or used on-site and acid- or <br />toxic-producing materials will not be used, stored, or <br />disturbed in quantities sufficient to adversely affect <br />any person, any property, or the environment. <br />2. <br />The November :L4, 1994 letter from the Offic• states that the <br />West Sunday Mina of>eration has been determined by the Office to be <br />a DMO for the following reason: <br />"1. Toxic-forming materials are or will be exposed or <br />disturbedi as a result of mining operations. Waste rock <br />dumps aria exposed to rain and snowmelt runoff possibly <br />causing offsite contamination." <br />Stormwater transport is not a concern for the following <br />reasons: <br />The West Sunday Mine is located in an grid region with <br />net evaporation, and is approximately six miles from the <br />nearest perennial streamflow. <br />The waste rock areas are stabilized and protected to <br />control esroaion, runon, and runoff. <br />The waste rock is not acid-generating, and the low radium <br />content of the rock is not highly mobile and is likely no <br />greater than that occurring naturally on the outcrop in <br />the surrounding area. <br />