2013-06-24_REVISION - M1990057

• Permit No: M1990057
• IBM Index Class Name: REVISION
• Doc Date: 6/24/2013
• Doc Name: AM-01 ADEQUACY REVIEW - 1
• From: DRMS
• To: OPERATOR
• Type & Sequence: AM1
• Email Name: MAC
• Email Name: TAK
• Media Type: D
• Archive: No

Letter to Nick Michael 6 June 24, 2013
AM -01 Application Adequacy Review File No. M- 1990 -057
6.3.10 Exhibit J — Proof of Mailing of Notices to Board of County Commissioners and Soil
Conservation District
No comment.
6.3.12 Exhibit L — Permanent Man -Made Structures
36. The structure agreements which were provided for the structures on the Philips and Mellott
properties did not list the structure owner or File Number on the Certification page. Please
submit revised copies of the Certification page with the structure owner and File Number
fields completed.
37. The Applicant listed Dale J & Deborah Wibbenmeyer as owners of a structure within 200ft
of the mill site; however, no structure agreement for the Wibbenmeyer's was provided.
Please identify the structure owned by the Wibbenmeyer's and provide a structure agreement
for said structure.
6.4.21 Exhibit U — Designated Mining Operation Environmental Protection Plan
38. The Applicant has listed Copper Sulfate as a chemical that will be stored at the mill site.
Please explain how Copper Sulfate will be used in the milling process, when it will be used
and specify the amount to be stored under `Section 4.2.7 — Chemical Reagent Inventory'.
39. The Applicant has stated that diesel will be stored at the mill site. The Division requires
secondary containment for fuel tanks. Describe the tank, secondary containment and
management of fluids collected by secondary containment. Also, depict the location of any
tanks on the appropriate map.
40. As required by Rule 6.4.21(6)(b), please submit a plan that describes how all designated
chemicals used in the extractive metallurgical process will be handled during periods of
Temporary Cessation. The plan should address stored chemicals /reagents as well as those
chemicals and reagents that are present in the mill circuits. The Division will require that all
pipelines and cells be drained at all times when the site is unmanned; please provide a
commitment to do so.
41. The Reclamation Plan states that chemicals and petroleum hydrocarbons will be removed
from the site and disposed. As required by Rule 6.4.21(6)(a), describe how all designated
chemicals will be disposed of and detoxified at the conclusion of operations so as to comply
with all applicable environmental protection and reclamation standards of the regulations.
42. Rule 6.4.21(18)(b), requires the Applicant to describe measures to prevent wildlife from
coming into contact with designated chemicals or toxic or acid forming chemicals. The TSF
is the only area within the Leadville Mill where wildlife could come into contact with
designated chemicals. How does the Operator intend to prevent wildlife from coming into
contact with the TSF? See additional comments under Exhibit B, No. 3.