2011-03-31_REVISION - M1977493

• Permit No: M1977493
• IBM Index Class Name: REVISION
• Doc Date: 3/31/2011
• Doc Name: Objectors' Prehearing Statement
• From: Objectors
• To: DRMS
• Type & Sequence: AM6
• Email Name: ECS
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
COLORADO
DIVISION OF.
RECLAMATION
MINING
SAFETY
John W. Hickenlooper
Governor
Mike King
F.xecutlve Director
Loretta Pinede
Director
Final Proposed Stipulations for Revised Water Monitoring Plan and EPP to be included as part of
approval of M1977-493, AM-06
1) A Comprehensive Water Monitoring Plan will be submitted for Division review and approval
which satisfies the requirements of Sections 3.1.6, 3.1.7 and 6.4.21(12) of the Hard Rock/Metal
Mining Rule. This plan will be incorporated into the permit through a technical revision (TR)
process that will assure opportunity for meaningful participation by parties identified at the AM-
06 pre-hearing conference. This TR will use previously collected data to establish permit
conditions that, at a minimum, will be protective of the currently prevailing surface water and
groundwater conditions.
The Division acknowledges that the water monitoring plan for any site should be a living
document that may be modified and improved as needed through the life of the permit through
the Technical Revision process to insure adequate protections. However, the Operator shall
make all attempts to provide a complete monitoring plan for the proposed operation based on the
conditions and operations contained and proposed in AM06 at this time.
Until this TR is approved by the Division for incorporation into the permit, the Operator is
precluded from placing additional tailings into the TSFs or operation of the milling facility at a
scale greater than what would be required to determine if the system is operational, or any other
previously unpermitted activities which may pose an additional risk to prevailing conditions,
including quality and quantity, in Eagle Park or Clinton Reservoirs. Normal site construction
activities as currently permitted or included in AM-06, ongoing site maintenance, water
treatment, and reclamation will be allowed to continue. The technical revision process to be
employed will adhere to the following steps:
When the Operator applies for the Comprehensive Water Monitoring Plan TR, they will
concurrently provide complete copies to the identified parties for technical review and
comment. The Operator will also waive the requirement that the Division must act on the
TR within 30 days to allow sufficient time for review, comment, and any required
modifications. Party technical comments to the TR will be submitted to the Division for
consideration within 30 days of receipt of the TR. The Division. will review the TR,
review and consider all technical comments submitted, and determine the final
composition of the Revision to be approved and incorporated into the permit. The
Division will act on the submittal within 60 days.
umce or Office of
Mined Land Reclamation Denver - Grand Junction • Durango Active and Inactive Mines