2010-08-20_PERMIT FILE - M2009076

Home Browse Search

Review of Venture Resources Inc. Proposal: Hukill Gulch Millsite; File No. M-2002-076 Page 2 operate their mill at 40 to 80 tpd, the bin will have to be filled about once or twice a week. In order to move this amount of material, 20 dump truck loads will travel over the mountain roads each week. The opportunity for spills or traffic accidents related to the increased truck traffic (and concomitant water pollution) is accordingly increased. Over the last decade, vehicle accidents, and related spills into Clear Creek and its tributaries, have been the most common reason for downstream water users to shut water intakes to avoid drinking water contamination. We further oppose imported fill feed because we are concerned that the disturbance of any mined rock that has for years been exposed to weathering inevitably exposes material that may be more leachable than that removed. Should the Division approve this imported material, the import area should be included in the permit and have a plan of remediation and run-on and run-off management. We also believe that any disturbance of a previously mined area or waste rock pile should trigger the requirements of a Designated Mining Operation, particularly the preparation of an Environmental Protection Plan (EPP) as required in 6.4.20 of the regulations. There is adequate information in the CERCLA records that demonstrate the acid or toxic producing properties of the previously mined areas in the Central City/Clear Creek Superfund Area. We seriously doubt that the tailings will be inert. As metallurgical recoveries of any process are never 100 percent, any leachate will doubtless contain metals that will be released to the environment. UCCWA believes that the tailings storage proposed as part of this project should also trigger the designation of this project as a Designated Mining operation as defined in Section 1.15 and require the preparation of an EPP under Section 6.4.20 of the regulations. On page 5 of the Adequacy Response-Stormwater Management Plan [file 7/29/2010, 2:43:44PM-JWD] Venture Resources state that the potentially most significant source of stormwater contamination is from waste rock on site. While we agree that the waste rock will be a significant source of stormwater contamination, we believe stormwater contamination from the proposed tailings impoundment is at least as great if not greater. We appreciate the opportunity to provide comments. Sincerely, Anne Beierle UCCWA Co-chair