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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY t <br />Department of Natural Resources J <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />/October 4, 2010 <br />Ryan McHale, PE <br />1/enture Resources, Inc. <br />COLORADO <br />D IV IS I ON OF <br />RECLAMATION <br />MINING <br />SAFETY <br />Bill Ritter, Jr. <br />Governor <br />Mike King <br />Executive Director <br />P.O. Box 1974 <br />Loretta E. Pineda <br />Idaho Springs, CO 80452 Director <br />RE: Hukill Gulch Millsite; File No. M-2009-076. Adequacy Review #2 & Tailings Impoundment <br />Design <br />Dear Mr. McHale, <br />The Division received your letter dated October 1, 2010 and September 14, 2010 in regards to <br />acceptable outslope angles for the mill tailings impoundment. After our meeting on September 30, <br />2010, the Division re-analyzed the proposed tailings impoundment design and stability of the proposed <br />impoundment to determine if a different outslope angle could be accepted. After careful consideration, <br />the Division maintains its stance outlined in the second adequacy review letter dated September 8, <br />2010. The long-term stability of the proposed upstream impoundment cannot be assured due to the <br />potential for liquefaction during an earthquake. The outslope angle of the impoundment is not the <br />limiting factor of the design. <br />The Division believes there are several options the Applicant should consider, if they decide to proceed. <br />They are summarized below: <br />1.) Submit a technical revision to the permit application for limited mill tailings disposal in Hukill <br />Gulch impounded by conventional earthen damming, such as the barrier bench described in the <br />permit application. <br />2.) Submit an amendment to the permit application to impound the mill tailings in multiple <br />conventional earthen dam embankments. <br />3.) Submit an amendment to the permit application to impound the mill tailings using a different <br />embankment raising method, such as downstream raises. <br />4.) Submit an amendment to the permit application to use a cemented paste technology to stabilize <br />the mill tailings. However, as discussed in the second adequacy review, the paste technology <br />may not resolve the liquefaction issue, and would exacerbate the revegetation problem and <br />would likely require a plan for placement and anchoring of growth medium. Also, the Operator <br />would likely have to import enough growth medium to support a rangeland plant community. <br />Along with these options, the Operator will need to submit the information and address the remaining <br />issues identified in the second adequacy review letter dated September 8, 2010. In accordance with <br />Rule 1.8.1, the Applicant may amend, or make technical revision to application for a permit under <br />consideration by the Office by filing a copy of such amendment or technical revision with the Office and <br />placing a copy with the County Clerk and Recorder. Any amendment or technical revision to an <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines