2009-04-06_REVISION - M1983141

• Permit No: M1983141
• IBM Index Class Name: REVISION
• Doc Date: 4/6/2009
• Doc Name: Adequacy Review
• From: DRMS
• To: Mount Royale Ventures, LLC
• Type & Sequence: TR6
• Email Name: ACS
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
April 6, 2009 V-11,
Mr. Matt Collins /
Mount Royale Ventures, LLC
9145 Sunshine Canyon Drive
Boulder, CO 80302 /
v
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RE: Adequacy Review, Technical Revision TR-06,
Cash and Who Do Mines, Permit No. M-1983-141
Dear Mr. Collins:
COLORADO
D I V I S 10 N O F
RECLAMATION
MINING
SAFETY
Bill Ritter, Jr.
Governor
Harris D. Sherman
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
The Division of Reclamation, Mining, and Safety (DRMS) has reviewed the above referenced application
for technical revision. The following items remain to be addressed:
1. Mount Royale Ventures is requesting approval to convey tailing from the Gold Hill Mill to the Cash
Mine for disposal into the mine workings. Tailing conveyance facilities, such as pipelines, drop structures,
distribution systems, monitoring and other appurtenances must be included in the area of affected lands and
fully described and approved in both permits M-1983-141 and Gold Hill Mill permit M-1994-117.
Description of the facilities must include designs and specifications. Inclusion of conveyance facilities into
permit M-1994-117 will require a technical revision to that permit. If conveyance structures will cross any
currently unpermitted land, then an amendment, not a technical revision is required for one or both of the
permits.
2. The DRMS must determine the representativeness of the materials analyzed for the report titled
"Description and Chemical Analysis of Proposed Injectate" included with the TR-06 application. This
determination requires, at a minimum, the following information.
a. A description of sample collection, preservation, and analysis for the data provided in the table titled
"Flotation Tailings Water Analysis - Mill Pond." In particular, for this data to be representative of water
that would report to the mine pool following tailing disposal underground, it would have to consist of
interstitial water from the tailing leaving the mill. If, as the title to the table indicates, the water analyzed
consist of water collected from the mill pond, the samples would not be representative due to comingling of
tailing water with water from precipitation. Even so, the dissolved solids concentrations in this water are
generally higher than in the Cash Mine pool, which argues against permitting of tailing disposal into the
underground workings.
b. A description of the representativeness of the TCLP results provided. The TCLP testing was done on
tailing produced when ITEC Environmental, Inc. was operating the Gold Hill Mill. ITEC, as part of their
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