2009-07-24_GENERAL DOCUMENTS - M2009076 (3)

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f • Venture Resources, Inc. PO Box 1974 (303) 619-6323 Idaho Springs} CO 80452 Fax: (303) 484-6369 ventureresources@att.net August 5, 2009 CO Division of Reclamation, Mining & Safety 1313 Sherman St., Room 215 Denver, CO 80203 Attn: Tony Waldron RE: Response to DRMS Letter of Aug. 3`d, requesting more information on remediation processes. Dear Mr. Waldron: Yes, I would be happy to elaborate on our proposed voluntary, remediation operation. First, though, I would like to clarify our position regarding certain language you mention in your letter of August 3`d. Venture Resources does not feel that our operation is "extracting" anything as the DRMS would have it defined. Hard Rock Rules, Rule I - Definitions states that: (17) "Extraction" means the removal of minerals and/or overburden from places of natural occurrence to surface locations. Please understand that we are not trying to be difficult and pick apart your letter. We simply do not feel that voluntarily cleaning up these abandoned mine waste rock piles is a "mining operation" or an "extraction" process as defined by the CO statutes or the DRMS rules. Our Petition for a Declaratory Order that is before the Mined Land Board is simply asking for clarity on whether or not the action of scooping-up and trucking off abandoned mine waste rock is a "mining operation" as defined by the DRMS Hard Rock Rules. • Venture Resources owns or leases over 270 acres of property contained within approximately 60 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 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 2,000 tons (Robert Fulton Lode) as examples. The impacted footprint of the dumps on these mining claims is always most usually under 1.5 acres each. Within this locale, we assembled a processing site containing around 40 acres ... within which a solid waste disposal impoundment for the newly processed, and cleaned, tailings will be constructed. The location is a dry gulch, the upper portion of Hukill Gulch, chosen for specific engineering and geologic design requirements. The directly impacted area for this impoundment will have a 700,000 ton total build-out with a 7.6 acre total build-out footprint. Carefully following CDPHE Solid Waste Regulations, this impoundment will undergo stringent reclamation measures as operations proceed. In April 2009 we submitted our final engineering in a Design and Operating Report to the CDPHE for this solid waste impoundment. Our business thinking can be summed up as: Crawl before you walk. Initially we have constructed a 40 ton/24hr day mobile processing plant. This plant is comprised of two enclosed trailers and one open trailer. This plant is located on our processing site and will deposit cleaned tailings into the impoundment area. Now the savvy mathematician will say that at 40 ton/day it will take us better than 13 years to process the 200,000 tons of material we currently have. Crawl before you walk ... we designed this initial phase to prove the concept, provide for a means of fine tuning the process, and to get into positive cash flow. We have also engineered a 400 ton/day processing facility. As we show success and develop funds, we will start to ramp • the process up and construct a larger facility. This will be a much more practical solution, taking advantage of better efficiencies through economies of scale. Page 1 of 3