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DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866 -3567 <br />FAX: (303) 832 -8106 <br />September 7, 2011 <br />Mr. Brian Egolf <br />Emerald Mining & Leasing, LLC <br />P.O. Box 628 <br />Creede, CO 81130 <br />Re: Bulldog Mine Operation, Permit No. M- 1977 -215, Technical Revision No. TR -17, Second <br />Dear Mr. Egolf: <br />Office of <br />Mined Land Reclamation <br />Adequacy Review Letter. <br />STATE OF COLORADO <br />SPOg201i <br />OIvioion of Reclamation, <br />Mining and Safety <br />COLORADO <br />D I V I S I O N O F <br />RECLAMATION <br />MINING <br />— &— <br />SAF ETY <br />John W. Hickenlooper <br />Governor <br />Mike King <br />Executive Director <br />Loretta E. Pineda <br />Director <br />On September 1, 2011 Randy McClure of Rio Grande Silver (RGS) met with Division staff in the Durango <br />Field Office regarding the technical revision referenced above, particularly to discuss the questions in the <br />Division's preliminary adequacy review letter of August 30, 2011. Satisfactory information was conveyed <br />by RGS during the discussion, and the Division expects to receive the written responses to those issues <br />shortly. <br />Part of the recent written responses submitted by RGS under this technical revision, in regard to site <br />preparation and liner installation, is included in a document written by Stephen Rogers, P.E., which <br />describes the details of the construction and certification of the two holding ponds and the HDPE liner <br />specifications. That document included sufficient detail to ensure that there will be adequate oversight and <br />reporting of each step in the earthwork and liner deployment to meet the requirements in Hard Rock/Metal <br />Rule 6.5 and 7. Unless there are changes anticipated to the actual holding pond structures, or variance to the <br />steps outlined in the written procedures, no further response is needed. Please clarify whether there will be <br />changes to the liner plan as presently set forth in Mr. Rogers' report. <br />During further review of the technical revision, several additional issues have been identified that need to be <br />addressed, primarily in regard to reclamation concerns. To clarify the basis of these questions, please be <br />aware that the Division treats each separate revision as a distinct action to be reviewed and then undertaken, <br />and that an appropriate amount of bond must be posted to accomplish the reclamation of the disturbance that <br />is currently approved and also within the scope of the revised plans for the permit. (Of course, some of the <br />reclamation tasks will become moot upon approval of subsequent permit revisions.) Therefore, in order to <br />assess the various disturbances and their reclamation tasks, please address or comment, as appropriate, on <br />each of the items listed below. <br />After the use of the temporary holding ponds, the liner materials and piping, etc., will have to be disposed of <br />onsite or offsite. Offsite disposal will involve removal of all inert materials and hauling them to a licensed <br />landfill. If there are any residues or sediments requiring special handling, neutralizing, or disposal, those <br />may have to go to a separate facility. Onsite disposal of certain materials could involve only the handling <br />for removal with minimal hauling costs. Will any of the piping or other items be buried below ground? <br />Please clarify the details of what the removal and disposal tasks will involve. <br />Office of <br />Denver • Grand Junction • Durango Active and Inactive Mines <br />