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P <br />3. Numerous other re-mining projects permitted by the Board throughout the <br />State. Few recent proposals due to long period of depressed metal prices and <br />failure of earlier projects. Recent resurgence of interest reflecting higher <br />precious metal prices and demonstrated by increased prospecting notice <br />activity, and inquiries received by DRMS. <br />B. This is mining and a permit is required - refer to AGO brief <br />C. Potential for environmental impacts, analysis of circumstances if Declaratory <br />Order is granted <br />1. Venture Resources states that mine dump removal and removal site <br />reclamation will be regulated by the counties through "excavation permits." <br />These dumps are chemically reactive, acidic and metalliferous. They require <br />specialized handling to minimize surface water, ground water, and other off- <br />site impact during excavation. Reclamation of underlying ground following <br />reclamation may require specialized processes; the application of biosolids <br />has its own set of challenges and potential problems. <br />2. Venture Resources states that acid runoff from mine dump stockpiles at the <br />mill will be managed using storm water controls. CDPHE has informed <br />DRMS that they do not have jurisdiction and will not impose regulatory <br />controls on dump stockpiles at the proposed mill. <br />3. The proposed mill will recirculate process water through the milling circuits, <br />water tanks or ponds of currently unknown (to DRMS) type or configuration, <br />and proposed tailing impoundments. CDPHE has informed DRMS that they <br />do not have jurisdiction and will not impose regulatory controls on water <br />balance or process water management and containment at the proposed mill. <br />4. Venture Resources tailing impoundment proposal describes a five cell <br />impoundment 200 feet in overall height in upper Hukill Gulch. It is not clear <br />from the Venture Resources proposal or from discussions with CDPHE what <br />agency, if any, will have regulatory authority over dam safety for the <br />impoundment(s). <br />5. It is not clear from the Venture Resources proposal what level or degree of <br />notification and public or other agency participation there will be in the <br />review of the proposed activities. <br />D. Potential for environmental impacts, analysis of circumstances if reclamation <br />permit is required <br />I . DRMS has extensive experience and expertise in the management, regulation, <br />and reclamation of sites where acidic and metalliferous materials are <br />excavated, dumped, stored and reclaimed. DRMS has extensive experience <br />and expertise in the management of reclamation projects using biosolids. <br />2. The Board has adopted specific regulations and DRMS has extensive <br />experience and expertise in the area of chemically reactive ore stockpile <br />facilities. <br />r:x