2009-04-08_GENERAL DOCUMENTS - M1994117

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03/06/2009 14:40 7205653497 MOUNT ROYALE VENTUR PAGE 03/04 EPA - Follow-up 3-6-09.doc 3/6/2009 2 of 3 Royale Ventures, LLC is the operator and permit holder of two Colorado Division of Reclamation,, Mining and Safety (DRMS) permits: M1983-141 encompassing the Cash Mine, and M1994-117 encompassing the Gold Hill Mill. These permits allow for hauling and processing of up to 70,000 tons of material per year. There is significant bonding associated with these permits that is dedicated toward the post- mining reclamation of the land within these permits, approximately 19 acres. The Cash Mine, as our original application for the UIC permit discussed, is to be reclaimed with a hydraulic seal. In addition to these two permits, MRV holds two Notices of Intent to Prospect (N0I) that allow for disturbance of up to an additional 8 acres of land. These NOI's were acquired in 2004. They are numbered P2004-006 and. P2004-007. In, 2005, Mr. Steen began application for an amendment (AM2) to the M1983-141 permit. Unable to properly complete this amendment, MRV and Matt Collins,. specifically, assumed responsibility for the completion of the permitting. In October of 2006, the DBMS granted approval of the AM2 amendment. The amendment contained language requesting the ability to emplace tailings (backfill) within the Cash Mine. The approval of AM2 was conditional, stipulating a submittal of a subsequent technical revision (TR05) concerning significant establishment of a water monitoring program., not previously required under the existing permit. Also contained within the AM2 approval, was significant hydro-geological characterization of the groundwater regime within the area of the permit boundaries. This was completed by Adrian Brown Consultants of Denver. Approval of AM2 and TR05 was granted by Mr. Torn Schreiner, Environmental Protection Specialist for the DRMS, who left the DBMS shortly thereafter, in the summer of 2007. In phone conversations with, and acknowledged by Mr., Sorenson, and as further evidenced in the gap in ARMS' electronic files between February 2006 and October 2006, there are many important documents missing, which include a large portion of the AM2 amendment. MRV committed to acquiring an EPA-UIC permit for an injection well in the AM2 documents. Pursuant to that, MRV applied to your office for just such a pertnit in December of 2007. Upon receipt of that permit (by rule) MRV, under assumption that the cotaversauons and permit dialogue with Mr. Tom Schreiner allowed backfilling, prepared to test a system for pumping mill tailings to the Cash Mine. In approximately August of 2008, MRV, under permitted activities associated with the NOI P2004-006, excavated and sampled two (2) historic. mine openings immediately adjacent to the M1994-117 permit boundary. Conversations between Mr. Carl Mount and Mr. Tony Waldron of the DRMS indicated that MRV's backfilling of those openings and subsequent revegetation would be acceptable to the State. In compliance with the EPA-UIC Class V permit by rule obtained by MRV, MRV tested the backfilling system by closing the holes excavated under P2004-006. One of these holes has been re-contoured and mulched for revegetation, the other, as you must. have seen yesterday, is prepared for final capping with rock and contouring.