1994-02-24_ENFORCEMENT - M1977378

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Amelia S. Whiting, Assistant Attorney General February 23, 1994 Page 2 the mine via the Terry Tunnel into Eureka Creek. DMG has approved the plugging plan, and has indicated that it considers water shutoff to be an essential requirement of any final closure; it does not consider perpetual treatment to be a valid option. The company has undertaken extensive technical studies of the feasibility of plugging the mine, including studies of the optimal design and placement of any plugs. Copies of these technical studies have been provided to DMG and WQCD; they are.. Simon Hydro-Search, February 11, 1992 Preliminary Characterization of the Hydrology and Water Chemistry of the Sunnyside Mine and Vicinity, San Juan County, Colorado. John F. Abel, Jr., Mining Engineer, March 10, 1993 Bulkhead Design for the Sunnyside Mine, Sunnyside Gold Corporation, An Echo Bay Company Simon Hydro-Search, March 12, 1993 Evaluations of Hydraulic and Geochemical Aspects of Proposed Bulkheads, Sunnyside Mine, San Juan County, Colorado. In numerous joint meetings with DMG and WQCD, and in correspondence with those agencies, several issues have been raised concerning the legal status of waters following the plugging of the mine. WQCD has directed SGC to obtain the views of your office on these issues. The purpose of this letter is to obtain clarification of the status of waters resulting from the plugging, so that final reclamation can be effected. Without resolution of these issues, the company cannot move forward to the final reclamation required by its DMG permit. The American Tunnel was first driven in the 1920s for a distance of approximately 5000 feet, to provide access to claims which are part of the Gold King property - property not owned by SGC, its predecessors or its affiliates. In the late 1950s, Standard Metals Corporation extended the American Tunnel approximately 3000 feet to obtain access to the Sunnyside property, which it then owned, and then another 2000 feet to connect with the main workings of the Sunnyside Mine. SGC acquired the assets of the Standard Metals Corporation in a 1985 bankruptcy proceeding. Among those assets is an agreement allowing SGC to use the first 8000 feet of the tunnel for access to its Sunnyside property and mine workings. The history of these changes to the American Tunnel is illustrated conceptually in the enclosed figures 1 through 4, which also includes a depiction of the post-plugging hydrologic regime. SGC requests that the Attorney General's Office advise SGC, DMG and WQCD of its position on two issues outlined below.