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feeder to the treatment process. 117here bulk hydrated lime is used, some type of dry feeder <br />• charges the lime continuously to either a batch or continuous mixer. ' <br />The precipitated metal hydroxides, sulfide minerals, and free metals are collected in the concentrate products <br />produced by the mill. Reference Exhibit C, 6.3.3(1)(m) for a description of the mineral processing operation. <br />According to the EPA's own work in this vicinity, this method achieves the following: <br />REPROCESSING: REPROCESSING WILL RESULT IN NEW TAILINGS THAT ARE NOT <br />RCRA WASTES. HOWEVER POTENTIAL LEACHATES FROM THE WASTE WILL <br />EXCEED AWQC**. REPROCESSING REDUCES MOBILITY, TOXICITY AND VOLUME <br />OF THE CONTAMINANTS. THIS ALTERNATIVE IS THE ONLY OPTION THAT <br />REDUCES VOLUME. REPROCESSING REDUCES EXISTING RISK TO HUMAN HEALTH <br />AND THE ENVIRONMENT. THIS OPTION IS THE MOST EXPENSIVE OF THE SIX <br />ALTERNATIVES EVALUATED EVEN CONSIDERING THE VALUE OF THE MINERALS <br />EXTRACTED. OVERALL, REPROCESSING IS A PERMANENT SOLUTION THAT <br />REDUCES EXPOSURE TO HUMAN HEALTH AND THE ENVIRONMENT. <br />**[Note by Venture Resources: Ambient Water Quality Criteria will be potentially exceeded, <br />meaning having a better state.] <br />EPA Record of Decision, ROD R08-88/019,1988 <br />6.4.20(15)(a-b) <br />Reference Exhibit C, 6.3.3(1)(e) for a description of the significant components of this operation, also locatable in <br />Exhibit E. <br />The Crusher Feed Pile sheltered & concrete paved base and containment benn shall be constructed within 2 weeks <br />• after pen-nit issuance, prior to full-time processing. <br />The Concrete Leachate Collection/Recycle Facility, Stormwater/Sedimentation Collection Pond, and first stage of <br />the Diversion Ditch have been constructed directly below the pre-existing waste rock within the proposed Tailings <br />Impoundment. This was done to immediately begin to mediate the toxic and acidic run-off from this material. <br />Throughout 2009, any leachate from this source has been treated with lime, greatly reducing the negative impact to <br />the environment while a permanent solution, through this pennit application, is being resolved. All construction was <br />supervised and inspected by a licensed CO professional engineer. As-built drawings are included in Exhibit E. <br />The Tailings Impoundment and Water Holding Pond liner will require inspections by DRMS. Exact dates of <br />construction are not immediately available. However, the DRMS has stated that the Operator shall "provide ten <br />days notice prior to commencement of geosynthetics installation ... DRMS will typically inspect ground <br />preparation prior to any geosynthetics being installed, and will be onsite during at least some of the HDPE seaming <br />operations. Testing of all HDPE seams is required during (concurrent with) installation. Both destructive and non- <br />destructive tests are required" Venture Resources commits to adhering to these notice requirements before liner <br />installation. <br />6.4.2U(16) <br />6.4. installation of the Tailings Impoundment composite liner system and the Water Holding Pond liner will require <br />Tile <br />a specific Quality Assurance/Control program. Refer to manufacturer installation and testing requirements provided <br />in the Composite Liner Submittal attached as an appendix to Exhibit C. <br />6.4.20(17)(a-b) <br />As previously mentioned in Exhibit D, 6.3.4(1)(x) and per the Mining Plan, Exhibit C 6.3.3(1)(b) & (c), there is no <br />overburden to be removed as part of the proposed operation. <br />• Considering the nature of poor topsoil conditions at this site (0-2" Cathedral soil and virtually no accumulation of <br />true A horizon topsoil, as previously described in Exhibit B) it will be challenging to salvage any significant <br />Page 29 of 31