2011-01-24_PERMIT FILE - M2011007 (10)

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Hard Rock/Metal Mining Permit Application Vv".•-?.M?S ?ti, Limited Impact Designated Mining Operation (I 10(d)) Venture Resources, Inc. - Robert Fulton Reclamation Q 42189 Revision 0: January 17, 2011 /-17-x/ Exhibit D - Reclamation Plan ???._••.....•- Overall Reclamation Summary: The proposed Venture Resources' project is a Reclamation Project. Venture Resources owns or leases over 250 acres of property contained within approximately 65 patented mining claims. These mining claims are located in the Russell Gulch and Virginia Canyon vicinity of both Clear Creek and Gilpin counties. For the most part, many of the claims are non-contiguous and located within a 1.5 mile radius of each other. Throughout our property there are approximately 200,000 tons of pre-existing abandoned mine waste rock dumps that have its origin from the late 1800's. We are not alone; there are many hundreds of thousands of tons of similar material located on other's properties in this vicinity. Depending on the individual claim, there may be a pile as large as 50,000 tons (Old Town Lode) down to 1,000 tons (Robert Fulton Lode) as examples. The impacted footprint of the dumps on these mining claims is almost always under 1.5 acres each. We recognized that to clean up these properties, these dumps will have to be reclaimed. They are not only an eyesore, but pose serious environmental damage due to acidic mine water run-off. Following the recommendations directly made in these publications: "Reclamation Feasibility Report - Virginia Canyon", CO DMG, December 2001 "Best Practices in Abandoned Mine Land Reclamation: the remediation of past mining activities", 2002 "EPA Record of Decision R08-88/019 - Central City, Idaho Springs", 1988 we began designing a voluntary program to manage the abandoned waste rock piles on our property. Various scenarios were analyzed for economic feasibility. It was quickly determined it would be an expensive adventure. Capping and revegetation were considered. This would add to the potential real estate value, but there was no immediate return on investment. Additionally, this method only "covered up" the real problem which is the pyritic, sulfide mineral content of the material that is the source of the acidic run-off. There would still be an effect on the groundwater in the future. Repeatedly, the documents referenced above indicate removal is the very best solution. We began doing metallurgical testing to determine whether or not it is feasible to process this material for any trace precious metal content to offset the initial capital outlay. It was determined that at today's prices, it was indeed feasible to construct a processing mill to extract the precious metals and all of the heavy metal contaminants from the waste rock. This brought about a private, voluntary business solution to cleanup an environmental problem caused by the abandoned mine waste rock. The EPA recognized this cleanup methodology in their ROD R08- 88/019: "REPROCESSING ALTERNATIVE: THE REPROCESSING ALTERNATIVE CONSIDERS THE TAILINGS AND WASTE ROCK PILES AS AN ECONOMIC RESOURCE AND RECOVERS THE INHERENT MONETARY VALUE WHILE GENERATING A WASTE WHICH MAY NOT BE DETRIMENTAL TO THE ENVIRONMENT." "REPROCESSING WOULD BE A PERMANENT SOLUTION THAT ELIMINATED COLLAPSE OF THE TAILINGS AND WASTE ROCK PILES. A NEW WASTE TAILINGS IS PRODUCED. LEACHING TESTS SHOW THAT THE NEW TAILINGS CAN BE DISPOSED INA MUNICIPAL LANDFILL. (emphasis added)" Page I of 5