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AUGUST 8, 2011 <br />MAY DAY MINE CLASS II — SUBMITTAL 2 REVIEW <br />PAGE 3 OF 15 <br />D. Water <br />Water uses at the site include potable, ore processing, drilling/extraction, sanitary, fire water <br />storage, dust mitigation, and filling of augmentation ponds. The applicant proposes meeting potable <br />needs for employees using bottled water and meeting other needs using a surface water right and a <br />groundwater right. The applicant states their operation will require 40 gpm (58,000 gpd), and that <br />75% (30 gpm or 44,000 gpd) will be continuously recycled in the ore processing cycle. Thus, it <br />appears the applicant is proposing that only 10 gpm of water will ultimately be consumed for uses <br />other than the ore processing cycle. <br />DOWR has confirmed the applicant holds two water rights. DOWR states the surface right is junior <br />and may be impacted by calls placed on the La Plata River. The groundwater right does not yet <br />have an associated well permit ,and DOWR states an augmentation plan will be needed to obtain the <br />well permit. <br />To address the implications of relying on junior water rights, the applicant's water balance needs to <br />detail how water will be used in dry years as well as average years (ie: augmentation filling rate and <br />potential, drilling/extraction, processing, dust mitigation, etc). The water balance also needs to <br />provide sufficient detail to demonstrate the feasibility of operating the mine operation with 10 gpm <br />of consumptive use. <br />II. Engineering Issues <br />A. Site Access <br />The applicant is currently proposing a single access to the site — an unpermitted private road <br />constructed in 2008. Although an existing United States Forest Service access road is commonly <br />understood to result in less technical and erosion complications than the private road, the applicant <br />has removed the USFS road from consideration due to federal permitting challenges. Thus, the <br />unpermitted private road is currently proposed to serve both primary and emergency access needs. <br />The new unpermitted private road runs from CR 124 to the La Plata River. Near the La Plata River, <br />the unpermitted road intersects a historic mine access road (also on private land). Both the new <br />unpermitted portion of the access road west of the La Plata River and the historic portion of the <br />access road east of the La Plata River are steep with minimum grades of 12 %. <br />The new unpermitted road was constructed in the absence of engineering design, specifications, and <br />testing and is currently failing and eroding toward adjacent wetlands. The historic portion of the <br />access road has hairpin curves and grades exceeding 15 %. While it is understood that roads <br />accessing mining operations are often in severe terrain and that minimizing disturbance is desirable, <br />the safety of routine employee traffic and of the ability for high -load vehicles such as emergency <br />vehicles, sanitary pumping trucks, and construction material, chemical and fuel delivery trucks to <br />negotiate the access road s unclear. <br />The original proposal (February 22, 2011) indicated that all vehicles would travel to the mine site. <br />This would include up to 25 employees, emergency vehicles, sanitary trucks, and construction <br />material, chemical and fuel delivery trucks. Responding to concerns regarding the feasible uses of <br />the access road, the applicant currently proposes a staging area adjacent to CR 124 where up to 15 <br />employees (lowered from 25) would park and transfer to ATV's. <br />PLANNING DEPARTMENT • 970.382.6263. • 1060 E. 2ND AVE. • DURANGO, COLORADO • 81301 <br />