2009-10-23_PERMIT FILE - M2009076 (19)

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According to the EPA's own work in this vicinity, this method achieves the following: REPROCESSING: REPROCESSING WILL RESULT IN NEW TAILINGS THAT ARE NOT RCRA WASTES. HOWEVER,POTENTIAL LEACHATES FROM THE WASTE WILL EXCEED AWQC**. REPROCESSING REDUCES MOBILITY, TOXICITY AND VOLUME OF THE CONTAMINANTS. THIS ALTERNATIVE IS THE ONLY OPTION THAT REDUCES VOLUME. REPROCESSING REDUCES EXISTING RISK TO HUMAN HEALTH AND THE ENVIRONMENT. THIS OPTION IS THE MOST EXPENSIVE OF THE SIX ALTERNATIVES EVALUATED EVEN CONSIDERING THE VALUE OF THE MINERALS EXTRACTED. OVERALL, REPROCESSING IS A PERMANENT SOLUTION THAT REDUCES EXPOSURE TO HUMAN HEALTH AND THE ENVIRONMENT. **[Note by Venture Resources: Ambient Water Quality Criteria will be potentially exceeded, meaning having a better state.] EPA Record of Decision, ROD R08-88/019, 1988 6.4.20(15)(a-b) Reference Exhibit C, 6.3.3(i)(e) for a description of the significant components of this operation, also locatable in Exhibit E. The Crusher Feed Pile concrete paved base and containment berm shall be constructed within 2 weeks after permit issuance, prior to full-time processing. The Concrete Leachate Collection/Recycle Facility, Stormwater/Sedimentation Collection Pond, and first stage of the Diversion Ditch have been constructed directly below the pre-existing waste rock within the proposed Tailings Impoundment. This was done to immediately begin to mediate the toxic and acidic run-off from this material. Throughout 2009, any leachate from this source has been treated with lime, greatly reducing the negative impact to the environment while a permanent solution, through this permit application, is being resolved. All construction was supervised and inspected by a licensed CO professional engineer. As-built drawings are included in Exhibit E. 6.4.20(16) There are no special construction measures that would require any specific Quality Assurance/Control programs above and beyond what would be performed under normal commercial construction or engineering practices. 6.4.20(17)(a-b) As previously metfi ioned in Exhibit D, 6.3.4(1)(a) and per the Mining Plan, Exhibit C 6.3.3(1)(b) & (c), there is no overburden to//Xie removed as part of the proposed operation and there will be no top soil reserved for reclamation. Due to the nature of poor topsoil conditions at this site (0-2", previously described in Exhibit B) it is impractical to salvage it for future reclamation uses. Within the Tailings Impoundment area, a great deal of the pre-existing surface is covered with abandoned mine waste rock. Once this material is removed for processing, it will be re- impounded in the same place and reclamation will proceed as outlined in Exhibit D. 6.4.20(17)(c)(iii) Inorder for revegetation to be done, plant growth medium will need to be imported and incorporated into the reclaimed surfaces. This medium consists of covering the impoundment area with a 4" blend of municipal Class-A bio-solids and wood chips. The Class-A bio-solids shall be purchased and trucked to the site. They will not need to be produced on-site and a composting program will not need to occur. Class-A bio-solids are produced by certified, carefully regulated (CDPBE jurisdiction) facilities to generate a product that is authorized for direct land application. The wood chips come from slash and woody refuse generated from beetle kill mitigation of local coniferous trees. It should be noted that the USFS has an ongoing major pine beetle kill remediation project and the availability of wood chips will not only be massive, but using this material will help the local community dispose of this "waste" product. The blend shall consist of an average 1 : 5 volumetric ratio of Class-A bio-solids (1.0 ton/cu. yd.) and woodchips (0.25 ton /cu. yd.). This blend shall be achieved by on-site mixing of the material utilizing a front-end loader. 26