2011-08-30_REVISION - M1977215

• Permit No: M1977215
• IBM Index Class Name: REVISION
• Doc Date: 8/30/2011
• Doc Name: Preliminary Adequacy Review Letter
• From: DRMS
• To: Emerald Mining & Leasing, LLC
• Type & Sequence: TR17
• Email Name: RCO
• Email Name: SSS
• Email Name: DMC
• Media Type: D
• Archive: No

DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
August 30, 2011
Mr. Brian Egolf
Emerald Mining & Leasing, LLC
P.O. Box 628
Creede, CO 81130
Dear Mr. Egolf:
Office of
Mined Land Reclamation
STATE OF COLORADO`
•
[ X t 7 , mi l 1
•
COLORADO
D I V I S I O N O F
RECLAMATION
MINING
— &—
SAFETY
John W. Hickenlooper
Governor
Mike King
Executive Director
Loretta E. Pirleda
Director
Re: Bulldog Mine Operation, Permit No. M- 1977 -215, Technical Revision No. TR -17, Preliminary
Adequacy Review Letter.
On August 17, 2011 the Division of Reclamation, Mining and Safety received the Technical Revision
named above, which involves the proposed construction of two temporary, lined holding ponds for
containment of the anticipated mine pool water that would be pumped is anticipated to be encountered
during construction of a new decline into the Bulldog Mine workings. The plan for construction of the
decline and the dewatering plan are not included in this technical revision. This technical revision for the
holding ponds proposes revisions to the mining plan and the reclamation plan.
The Division is reviewing the technical revision to determine whether it is adequate for approval. During
the Division's review several issues and concerns have been identified, primarily concerning the integrity of
the constructed holding ponds and the water quality. As mentioned above, although this TR -17 does not
include the dewatering and filling of the holding ponds, it is appropriate to identify possible future
hydrologic concerns now that may require time to address. Please address each of the technical items listed
below.
Regarding hydrologic issues of surface water and groundwater, it may be helpful to refer to Hard
Rock/Metal Rules 3.1.6, 3.1.7 and 6.4.7. For structural and containment issues concerning the liners, please
refer to Hard Rock/Metal Rule 6.5. The Bulldog Mine permit is not currently permitted as a designated
mining operation (DMO) and is normally exempt from requirements under Hard Rock/Metal Rule 7.
However, portions of Rule 7 are pertinent to this revision, specifically regarding the engineering design,
construction, and certification of the lined holding ponds. Please see Hard Rock/Metal Rules 7.3 and 7.4.
The plan is for constructing two separate holding ponds, with similar embankments constructed of onsite
earthen materials with containment assured by impermeable liner systems. The basic design includes
grading and shaping to create the necessary depression and embankment. In general, the Division will
require that the pond bottom and sides be compacted and smooth (free of sharp protrusions) to avoid
breaching or rending of the liner when the pond is filled. It is likely that the earthen materials that comprise
the 9360 pad, from which Pond #1 will be constructed, contain some coarse material that could perforate or
breach the liner, and should be avoided. Please describe how the sub -base (surfaces of the floor and sides)
will be adequately cleared of such materials.
Office of
Denver • Grand Junction • Durango Active and Inactive Mines