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

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s nr 1• -3- August 5, 2009 • Please understand, I intended this to be a brief synopsis of the operations. Further engineering elaboration can be found in our Hukill Gulch Solid Waste Facility Design and Operating Report April 2009 that we have submitted earlier with the CDPHE. It is our hope that it can be seen that we have taken every effort to follow the laws that the CO legislature has prescribed and the subsequent rules that the appropriate jurisdictional division (ie CDPHE) have promulgated. We are not trying to maneuver through any loopholes. Every step of the way there is clear oversight that this processes is managed carefully. Where the problem enters is when people begin to wonder about "what if' scenarios. Well, my crystal ball doesn't work too well, but I will try to address some of those concerns. "What if you guys start to open up some underground mines?" In that event we would apply for a Mining Permit with the DRMS, as we have already successfully done with the Emma Lode (permit M-2008-037). Remember, crawl before you walk. It will be many years before we are in any situation to extract ore from this mine. By that time it is likely that the solid waste impoundment we have designed for the dump operation will be full. In any event, before any different waste is considered for the impoundment, a waste stream characterization will have to be done and approved prior to depositing. Most likely a new imnnnnrlment nell will have to be enaineererl to anrnmmorlate this different wade dream "What if you guys start processing other people's dumps?" As outlined above, we have plenty of our own material to worry about for the foreseeable future. We do anticipate, however, that this program will be successful and be a model for cleanup projects. In the event the scope grows, we can foresee applying for a Certificate of Designation with the Clear Creek County Commissioners to allow our facility to accept material from other sources - becoming a sort of custom mill. Again, waste stream characterization and subsequent engineering is prescribed by law before anything can change here. Also, there is nothing to say that this impoundment cannot be "converted" or "coordinated" from one jurisdiction to another depending on the future changes in operating conditions. An example of this is the Keenesburg Fly Ash impoundment. • Our intentions are to do what we have applied to do, namely cleanup these waste rock dumps. Since the CDPHE Solid Waste Division changed their position, we have approached the CDPHE Voluntary Cleanup Program (specifically Fonda Apostolopoulos) to see if there is a better fit with them. If there is indeed a concern about the activity at the waste rock pile location, they could bring their oversight to that part of the operation with a nod from the DRMS. The CDPHE regulations would still be in effect for the offsite processing and waste disposal. We feel a poor precedent would be set if the Mined Land Board decides picking up and moving these waste rock piles is a "mining operation". This would most likely dissuade others from voluntarily cleaning up their property if a burdensome mining permit is required. I hope that I have provided enough elaboration on our process. If you need more technical information, please let me know. You may also contact me at 303-619-6323 or ventureresources@att.net. Sincerely, Venture Resources, Inc. grn ' 171e-#M4- Ryan J. McHale, PE Vice President cc: Fonda Apostolopoulos, CDPHE Remedial Programs 0