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integrity of the tailings pond liner. The process water from the pond that was used to slurry these <br />mill tailings to these prospect holes has already migrated through joints and fractures and entered <br />the ground water. This seriously compromises any future test results from the required quarterly <br />monitoring of these wells. These sites need to be cleaned of any mill waste prior to being capped <br />with rock to prevent future contamination of the ground water and problems with the monitoring <br />well test results. <br />As a "degreed professional," an "industry leader," a "responsible mine operator," and the <br />General Manager of a company that considers environmental protection a core value," Matt <br />Collins must have known that discharging mill tailings into two prospect holes and the Cash <br />Mine had not been approved by the DRMS prior to his starting this activity. Where is the <br />Technical Revision Approval letter from the DBMS incorporating the terms of a TR requesting <br />to dispose of mill tailings in mine workings into Permit No. M-1994-117? The Rule <br />Authorization letter from the EPA specifically required MRV to "satisfy any other federal, state <br />or local regulations that may apply" to the emplacement of tailings into existing underground <br />workings or openings. Obviously, Mr. Collins was on notice that he had to obtain authorization <br />from the DBMS prior to discharging mill tailings anywhere other than in the approved lined <br />tailings pond adjacent to the Gold Hill Mill. <br />The fact that this was being done to facilitate the importation of ore from Tom Hendricks' <br />Cross Mine for processing in the Gold Hill Mill with the discharge of uncemented tailings into <br />mine workings that did not belong to either MRV or Calais Resources does not seem to have <br />been a consideration of the people involved in this ill-conceived plan. As one of the owners of <br />the sites chosen for this mill tailings waste disposal, I assure you that I have more than a passing <br />interest in this scheme. I do not know of anyone other than Matt Collins who believes that <br />discharging up to 70,000 tons of uncemented waste and millions of gallons of chemical-laden <br />process water into their mine workings every year would not be a very legitimate environmental <br />concern for a property owner. Incidentally, disposing of even a small fraction of this amount of <br />mill tailings in the Cash and Who Do Mines would render them unusable for future mining <br />operations. These are small mines, and there is not enough space to hold any appreciable tonnage <br />of mill waste without completely filling the working levels and the mine shaft. This is only one <br />of several'serious objections that I have with MRV's plan to emplace mill tailings in mine <br />workings. <br />Furthermore, I do not know of anything that would legally allow MRV to use our <br />property and mine workings as waste disposal sites for imported ore. Everyone concerned with <br />the Gold Hill Mill permit (including Tom Hendricks and his attorney, John Henderson) has long <br />been aware that importing ore from offsite would be in violation of the Boulder County Land <br />Use Code. Matt Collins has been in possession of the complete Boulder County file for the Gold <br />Hill Mill for several years, and had full knowledge of the restrictions on importing ore from <br />offsite sources. <br />If the Gold Hill Project had been properly managed, a second, larger tailings pond would <br />have been constructed with some of the $8 million that was spent on this project during the last <br />four years. Then there would not have been any need to dispose of uncemented mill tailings in <br />mine workings. As things stand now, the Gold Hill Mill's tailings pond is filled to capacity, and <br />Page 2 of 3