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<br />Mr. Bruce Humphries <br />December 28, 1994 <br />Page 4 <br />In compliance: with 31-32-1ib(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 ~~ollution. Subsequent to field concurrence from <br />Mr. James Dillie during his November, 1993 mine inspection, Umetco, <br />followed by EFNI, h.as 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 West Sunday Mina (Permit Number COR- <br />040107), under tk:e Colorado Discharge Permit System (CDPS). <br />Following issuance of the permit, Umetco submitted a Stormwater <br />Management Plan, which includes the Best Management Practices (BMP) <br />which had been d.iscusaed in the field during the 1993 mine <br />inspection. A copy of the Stormwater Management Plan for the West <br />Sunday Mine is included as Attachment 1. The Stormwater Management <br />Plan includes a copy oP the CDPS permit for the West Sunday and <br />other mines and a map of the west Sunday property. The BMP's have <br />been implemented, and are effective in preventing any stormwater <br />transport of potential contaminants from the waste rock areas. The <br />permit requires than annual inspections assessing the adequacy of <br />the BMP's be reported to the CDH. <br />In summary, EF'NI believes that the West Sunday Mine does not <br />meet 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 />