2011-03-04_PERMIT FILE - M2011007 (6)

Home Browse Search

f UPPER CLEAR CREEK WATERSHED ASSOClATl4N P, o, BOX 3WO M"O SPRINGS, CO 804452 March 4, 2011 Mr. Jared Ebert Department of Reclamation, Mining and Safety 1313 Sherman St., Room 215 Denver, CO 80203 f RE: Venture Resources Inc. Pro Robert Fulton Reclamation, DRMS file 9M-2011-007 This letter is in response to the application to conduct surface extraction of hard rock materials and reclamation for hauling o waste rock from the Robert Fulton Reclamation to the processing site at Hukill Gulch, submitted by Venture Resources. The Upper Clear Creek Watershed Association supports legitimate mining ventures that will maintain or improve water quality in Clear Creek. Clear Creek provides drinking water to 300,000 Colorado citizens. This is a highly used and over allocated stream; as such, water quality within this stream is critical to its many users. We believe that Venture Resources is taking a prudent approach by using the relatively small 1,000 ton waste pile at the Robert Fulton mine site as the first feed for its mobile mill. In addition, Venture Resources has addressed reclamation at the site from which the waste rock will be removed. This should be the case for each reclamation site. We have ongoing concerns regarding the hauling, processing and disposal of waste rock: • Storm water contamination from the site is always a concern. In accordance with its Storm Water Management Plan, Venture Resources should install its BMPs before work begins. In addition, all BMPs should be inspected at least every 2 weeks or after runoff events (whichever is more frequent). • We are concerned about the possibility of spills from the dump trucks hauling the rock. In paragraph 6.4.21(6)(a) of Exhibit U - Environmental Protection Plan, Venture Resources has described procedures to minimize and mitigate against spills. These include not overfilling the loader and/or dump truck that will haul the material, and training the operator to stop the machine and shovel up any spilled material back into the haulage equipment. Two ways in which the risk of spills can be reduced are: I . The operator should not only be trained to avoid overfilling and to shovel up any and all spills on the road; the operator should sign an affidavit noting such training and the order to implement the training; and, 2. The access roads should be maintained in good enough shape to accommodate the trucks they will be using, ensuring the loads will stay in the truck • Although the host rocks in the Idaho Springs-Central City Mining Districts are similar (schist and granite gneiss of the Idaho Springs Formation and Tertiary monzonite and quartz monzonite), vein mineralogy varies, primarily in the amount of pyrite in the ores. Consequently, a composite grab sample should be taken from each waste rock site. and provided to UCCWA for identification, and a description ...? .uc3 bah?` -liii5lk»bSa= e - ., ..?_\oe .. _ °-Mead