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tl <br />CLEAR CREEK "tershed6 <br />WATERSHED <br />FOUNDATION <br />2060 Miner Street • P.O. Box 1963 - Idaho Springs, CO 80452 - 303,567.2699 • info @clearcreekwater.org - wsnmclearcreekwater.org <br />November 9, 2009 <br />Colorado Division of Reclamation, Mining, and Safety <br />Mined Land Reclamation Board <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />SUBJECT: Clear Creek Watershed Foundation Comment Letter regarding: <br />L- 0923 -01 -C PUBLIC NOTICE Empress Gold Mining & Milling, Inc. <br />Hard Rock/Metal Mining Limited Impact (110) Reclamation Permit for the Stanley Mines <br />Dear Colorado Mined Land Reclamation Board Members, <br />The Clear Creek Watershed Foundation is a 501(c)3 non - profit corporation and is the Good Samaritan <br />agent for EPA Region 8 for clean -up of orphan mine wastes in the Clear Creek /Gilpin Superfund Study <br />Area, acting under authorities of CERCLA Section 107 (d) (1). Our review of the subject application <br />reveals what appear to be significant deficiencies and /or misstatements. <br />Paragraph 14 response is believed to be in error. <br />The Stanley Mine is hydraulically connected to Clear Creek Segment 2, which is on the 303d List <br />of impaired waters of the United States. This segment is listed for exceedences of heavy metals. <br />The entry in subject application Paragraph 14 should have listed the acidic and toxic - forming <br />materials exposed or disturbed both surface and subsurface as a result of this proposed mining <br />operation. <br />Further, it should discuss the dewatering and treatment plan for flooded subsurface workings <br />where both waste rock and treated mill tailings will displace large quantities of contaminated <br />water. <br />Exhibit C: Mining Plan shows significant deficiencies. <br />Paragraph H does not discuss the linkage to Clear Creek Segment 2. <br />Paragraph I appears to be false. <br />Paragraph L does not discuss the hydrologic perturbations within the mine from the deposition of <br />700 tons /day of slurry and an unspecified quantity of waste rock. <br />The statement in Section 11, B. Tailings appears to be false. "Tailings storage areas are isolated <br />and they are located a minimum of one hundred feet from the surface." The applicant's Exhibit A: <br />Stanley Gold Mines Companv Ltd Longitudinal Section Vertical shows this placement is well <br />below the elevation of Clear Creek, which would displace large volumes of water currently filling <br />the flooded mine workings into the surface waters of Clear Creek. <br />r There are no descriptions of the dewatering plans for the Stanley Mines or descriptions of <br />treatment of the existing waters within the workings. <br />None of the paragraphs discuss the cadmium problem — a significant pollutant impairing Clear <br />Creek. <br />There are no engineering descriptions or process drawings describing the proposed reclamation. <br />There are no engineering descriptions or process drawings supporting the stated supposition that <br />`seepage of water from this mine into the surrounding groundwater will not be a detriment to <br />groundwater quality." <br />Exhibit D: Reclamation Plan is remarkable. <br />Storage of waste rock and more than 700 tonslday of milled rock over 10 years will be secured <br />underground forever and public health safety, and welfare will be maintained by a padlock on <br />the shaft house with no continued dewatering or treatment. <br />