2009-04-08_GENERAL DOCUMENTS - M1994117

Home Browse Search

Mark A. Steen P.O. Box 1523 Longmont, Colorado 80502 Phone: (303) 651-2985 April 7, 2009 Division of Reclamation, Mining & Safety Mr. Allen Sorenson Senior Environmental Protection Specialist 1313 Sherman Street, Room 215 Denver, Colorado 80203 Y RE: Gold Hill Mill - Permit No. M-1994-117 v Cash & Who Do Mines - Permit No. M-1983-141 RECFivFp NOI P2004-006 & NOI P2004-007 APR 0 8 I-ituy ? Dear Mr. Sorenson, owisionotKwiamation, wftwdSafely Attached are two letters from Mount Royale Ventures' General Manager, Matt Collins, to Valois Shea at the Environmental Protection Agency that I believe you will find to be of interest. Hidden within Mr. Collins' version of the "significant miscommunication" regarding his permitting and operational activities is the "assumption that the conversations and permit dialogue with Mr. Tom Schreiner allowed backfilling" of "two (2) historic mine openings immediately adjacent" to the Gold Hill Mill permit boundary. In other words, Mr. Collins was supposedly relying on conversations and dialogue with Mr. Schreiner when he began pumping mill tailings into mine workings rather than into the permitted tailings pond. On March 6, 2009, Mr. Collins filed Technical Revision No.6 for the Cash and Who Do Mines Permit No. M-1983- 141. He did this in order to resolve a "conflict within the permit documents" and to "obtain a separate Technical Revision to the permit that, in fact, unequivocally addresses the issue" of underground tailings emplacement. I am unaware of any written communication approving the discharge of mill tailings anywhere but inside the lined tailings pond. My review of the Gold Hill Mill permit file does not indicate that the DRMS was ever requested to allow the discharge of tailings off the permitted millsite. In fact, just prior to the August discharge into the prospect holes, Mr. Collins filed the Annual Report for the Gold Hill Mill on July 25, 2008 with his standard statement that "MRV continued to operate the Gold Hill Mill as a zero-discharge facility." I cannot find anything in the Rules and Regulations that would allow an NOI to be converted to a permitted tailings disposal site. Apparently, every historic mine and prospect pit located within the area encompassed by the Prospecting Permits was a potential tailings disposal site as an "associated mine working" under the UIC-Class V Permit that Mr. Collins obtained from the EPA. None of the affected landowners were notified by MRV of its plans to dispose of mill tailings in any of their mine workings. The two prospect holes that were filled with mill waste pumped directly from the tailings pond are in close proximity to the monitoring wells that are used to determine the Pagel of 3