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Board determined that the dump removal would not constitute a mining activity requiring a Mined Land <br />Reclamation Permit since the removal was part of an approved Storm Water Management Plan. This <br />plan may or may not be carried out depending on approvals of new permitting procedures at the Pride <br />of the West Mill and other factors including a determination by the Division that the previous Board <br />action is still appropriate. However, current circumstances may be materially different since a possible <br />active mining operation is under consideration. <br />As stated on Page 4, item 11 of Section III of Form 2 of the NOI, any material to be buried in the existing <br />dump would first be characterized to its potential for generating Acid Mine Drainage (acid base potential <br />and neutralization), and for its potential to contribute metals to the existing dump (toxicity test). If an <br />identifiable potential exists for increased contribution of metals to the Animas River (degradation), then <br />the application states that the trench will be lined with PVC or LDPE liner material to prevent contact <br />with other dump material. The Application also states that the dump material would be covered with <br />native material borrowed from existing native (non -acid generating) site material. If it is deemed <br />desirable, a GCL clay liner may be placed on top of the waste material before the cover is applied. <br />If the Division believes that it is desirable, the sedimentation material may be buried at an alternate <br />location on the mine site that contains no mine or mill tailings and is located outside of any drainage <br />channels, with the material enclosed in a geo- synthetic liner as described above. However, Colorado <br />Goldfields Inc. believes that either approach will result in no adverse impact on existing ground water <br />resources or degradation of the Animas River water quality. <br />