2012-08-29_PERMIT FILE - M2012032

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locating a processing facility inside the mine, as would reasonably be expected. When such detailed plans and studies related to the mill are publicly available, the Division should provide another opportunity to interested citizens to comment on those details and allow them to be considered in context of the entire permit application. As Star Mine notes on page 37 of Exhibit T, "the mill is currently being designed." Approval, with or without conditions, would be premature without consideration of the finished designs. As proposed, the reopening of the Revenue Mine presents exciting opportunities for the revival of a traditional industry in Ouray County: the mine is small and impacts can, in theory, be addressed; some of the historic contamination problems associated with the site will be addressed; the mill will be modem and represents a substantial investment to the community; and, again in theory, an underground mill offers the opportunity to achieve many desirable changes from the historic problems associated with high- country mining, namely an opportunity to reduce the amount of final waste product and to reduce haulage over county roads in the Yankee Boy Basin area, which are heavily used in summer months for recreation and tourism. With a brand new design on the way, Star Mines asserts that this new - generation mill will produce tailing waste that is completely inert, a commendable goal. But the Revenue Mine also presents opportunities for an untested design to be approved without enough vetting. Colorado does not appear to have another similar underground mill operating and the Revenue would be in a class by itself. It may be worth noting, however, a page from the history books and how Colorado's past experience with underground milling -- at the Eagle Mine near Minturn -- turned into a thorny Superfund problem ( http:// www .epa.gov /region8 /superfund/co /eagle /index.html). The difficult feat of underground milling at the Revenue may also be further complicated by the fact that it is a very wet mine. In any case, the Revenue is a proving ground for the future, and it is imperative that the designs and the analysis be robust enough to withstand any unsure footing that may be encountered down the road. While it is commendable that Star Mine Operations has commissioned designs for the mill that require all tailings generated at the mill to be chemically inert and plans to prevent any reactive tailings that are created from being disposed of at the Revenue Mine site, it doesn't seem realistic. The applicant has proposed annual testing of tailings using an SPLP test, but this testing should be done at least on a quarterly basis. In addition, the applicant is proposing that no liners will be used at the two tailings waste piles, based on the assumption that the tailings will be inert. (See discussion in Exhibit T, pages 12 -13.) The lack of liners at the waste ponds -- and elsewhere on site, such as the Mine Water Pond -- invites questions about the long -term stability of the piles and the weathering they will endure over time while forgoing a prudent precaution that could prevent harm to the mine's environmental conditions. There is also an oversight in the application in which an offsite disposal site has not been identified, should offsite disposal become necessary. Since the mill has not been designed or constructed, and no tailings have been produced yet, it is impossible to know whether the tails will, in truth, be inert and suitable for the low -key disposal that Star Mine Operations describes in the application. Star Mines has proposed sampling the mill tailings for moisture content every 2,000 tons, yet proposes a bare -bones and