1988-08-24_ENFORCEMENT - M1977378 ‎(2)‎

• Permit No: M1977378
• IBM Index Class Name: ENFORCEMENT
• Doc Date: 8/24/1988
• Doc Name: Notice of Possible Violation
• From: Sunnyside Gold Corp
• To: MLRD
• Media Type: D
• Archive: No

999
SL?l1 NYSIDE GOLD CORPORATION
AN ECHO DAY COMPANY
P.O. Box 177 .Silverton, CO 81433
Phone [phone] .Telecopy [phone]
August 23, 1988
Mr. Fred Banta - Director
Department of Natural Resources '
Mined Land Reclamation Division `�O
215 Centennial Building <G w 41988
1313 Sherman Street MINED „�
Denver, Colorado 80203-2273
RECLAMATION UIV1810N
RE: "Sunnyside Mine", File No. M-77-378, San Juan County
I. ice of Possible Violation dated 8-1-88/received 8-8-88
Dear Mr. Banta,
The above referenced "Notice of Possible Violation" concerning waste
storage in Sunnyside Basin came as a complete surprise to myself and Bill
Goodhard - General Manager. We each assumed our current responsibilities
in July, 1988 and although we were aware that stipulations to the Permit
Amendment 03 existed, we were under the assumption that they were to be
addressed as the open pit project matured (except the BLM's cultural
resource inventory) and not as a condition before startup. Similar assumptions
were made by the people in charge before us (see attachments).
We believe the "Notice of Possible Violation" is a direct result of
our poor communication with the Division and not because of a violation
of the terms of our Permit. Because of the time constraints involved, this
matter will regretfully end up before the Board instead of being worked
out through discussions with Division which is our preference. The
following discussion is the reasons why we believe no violation of the terms
of our permit exists and a partial update (a complete submittal will take
more time) on the project.
The scope of the "open-pit project" was drastically reduced from the
plans submitted in the Amendment. This reduction was a result of detailed
Geologic and Engineering studies of the preliminary design and the final
product resulted in a reduction of waste volume generated from 2,346,000
cubic yards to 100,000 cubic yards. This reduction eliminated the need
for permanent disposal sites for waste (Waste Rock Dumps No. 1 and No. 2)
as the volume to be generated was less than that estimated for backfilling
the Lake Emma void (385,000 cubic yards) . Since backfilling the Lake Emma
void was a requirement of the Consolidated Permit and reiterated in Amend-
ment 03, temporary waste areas were established close to the hole for
backfilling when enough volume could be accounted for to complete the project
in one construction season.