2009-03-06_REVISION - M1983141

• Permit No: M1983141
• IBM Index Class Name: REVISION
• Doc Date: 3/6/2009
• Doc Name: Submittal
• From: Mount Royale Ventures, LLC
• To: DRMS
• Type & Sequence: TR6
• Email Name: ACS
• Media Type: D
• Archive: No

Mr. Allen Sorenson - DRMS 3/5/2009 2 of 3
have no effect on such a plan, were it required. Emplacement of the tailings will
have a positive impact on the mine pool.
2) Pursuant to previous submittals to the DRMS, and the Code of Federal
Regulations Title 40(CFR40) § 144 inclusive, and specifically § 146.5(e)(8), MRV
has obtained an Underground Injection Control (UIC) Class V permit (by rule)
authorization from the Environmental Protection Agency (EPA) for the proposed
emplacement of mill tailings, from the Gold Hill Mill, underground in the Cash
Mine and associated properties. This is evidenced in the attached letter from the
EPA, dated January 07, 2008.
3) As further evidence and for clarification regarding the application for the tailings,
MRV submits the complete application to the EPA, for the permitting of the
tailings emplacement, less form EPA form 7520 which is duplicative of
information presented. In this application, the DRMS will find comprehensive
characterization of the tailings to be emplaced (injectate), the transport water
associated with the injectate (tailings pond water) and the receiving ground water
(Cash Mine Pool). Again, emplacement of the tailings will have a positive impact
on the mine pool.
4) The tailings to be emplaced may or may not be cemented via addition of
pozzolanic additive. The flexibility to allow for cemented or uncemented tails is
requested. The addition of a cementing agent is not necessary from a chemical
mobility standpoint, as the proposed injectate is benign in nature. Underground
stability of the injectate is expected to be excellent, during and after decantation
of transport water. This is especially true when receiving voids are prepared with
broken rock and/or burlap or other water permeable filtering media. The addition
of cementation, if economic, would allow for additional flexibility in the
approved mining method. Evidence of tailing stability in the area of similar
materials can be seen in Four Mile Canyon, where Four Mile Creek has cut
historic tailings, leaving a near vertical slope. Further, the Slide Mine VCUP
addressed stability of an entire historic tailings pond located on the steep northern
slope of Gold Hill. Today, despite many years of erosion due to storm events and
seasonal snow melt, the near vertical face of the Slide tailings are visible. In an
entirely contained environment underground, MRV asserts that tailings stability
will be excellent.
5) MRV believes that tailings backfill was approved in AM2, as part of the "Cash
Mine Permit Revision Hydrogeology - Sept. 11, 2006" report prepared by Adrian
Brown (6.2.3 Mine Backfilling) and also accepted via TR05, in the "Cash Mine
Comprehensive Water Monitoring Plan - Nov. 6, 2006" also prepared by Adrian
Brown (2.7 Mining). Conflicting statements in the "Cash Mine Non-DMO
Certification - Dec. 10, 2006" report by Adrian Brown (2.4) & (2.5) indicate that
at Technical Revision would address the tailings backfill at a later date. In order
to eliminate this confusion, MRV submits this TR. These statements did discuss
M1983-141 TR06 Request 3-5-09.doc