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Re: Dunphy777 post# 23365

Saturday, 09/13/2014 10:10:01 AM

Saturday, September 13, 2014 10:10:01 AM

Post# of 54720
Copied and highlighted-- FACTUAL, pertinent INFO, please stickie:

They aren't digging permits. There are several permits that need to be in place. One permit will be the ground water protection permit. Someone has to approach the state with their plan of operations and a flow chart. The state will then determine whether the need a permit or not. But it is the state's decision, not the party submitting the information. Another permit is for storm water runoff. When a party is disturbing soil or similar material, they need to have a plan in place to prevent storm runoff water carrying sediment to enter the waters of The United States. The government considers almost any gully that runs water during a storm to be "waters of the United States". This isn't an optional permit, it is required. I don't know where you live but now days, at any type of construction, subdivision, high way construction etc you will see hay bales, silt fences and other material bordering the site. The same thing would apply to disturbing the tailings.

In one of the videos posted on their web site, there is a picture of what appears to be a crushing and screening operation. The state requires air quality permits for the operation of this type of equipment. There are no exceptions.

The Knelson concentrators will generate new tailings. these tailings will have to be contained in a new tailings pond. In most western states, the state engineer needs to review the design. The laws vary from state to state but usually, depending on the volume contained and the height of the retaining structure, the state engineer might require that the enclosure be designed by a professional engineer. I doubt that MNGG's pond will require this but it is up the state engineer to determine this.

If MNGG has an attorney worth his salt, he should have made sure that the owner has all of these permits in place.








gitreal Member Profile gitreal Member Level Friday, September 12, 2014 9:08:58 PM
Re: Dunphy777 post# 23365 Post # of 23399
Great explanation, Dunphy! Just for clarification, in Arizona there is no "State Engineer". All of the engineering issues that might affect environmental conditions go through the APP process. The APP Unit has engineers on staff, and the applicant pays for ADEQ's engineers time to review the applications and the engineering (plans, drawings, etc.). I believe it is $117/hr. although it maybe went up recently.

Actually, as for the tailings, if there is a dam involved, there is a State dam inspector. I almost forgot about that one. The APP process pulls all of the various agencies together - you cannot just comply with part of it - it is all or nothing. The process is very expensive - there is a nonrefundable application fee, and then every hour the state spends reviewing it, they charge you (the applicant). Their review fees can go into the hundreds of thousands of dollars. And, there are the consulting fees you will have to pay, and the testing and the well installations, etc. It is a long, laborious, and expensive process.

Even without a dam (just a pond), you can bet that an engineered liner will need to be designed, approved, and constructed. Everything must be reviewed and stamped by an AZ PE.

No small mine that I know of has ever successfully gone through the whole process and received an APP. Some mines are exempt, but must prove that the ore is completely inert, and very few metal ores can pass the tests. The tailings at Congress will almost certainly fail for acid producing potential, and probably for metals (arsenic and lead) as well.

And then there is MSHA........you can probably attest to how hard it is to make those guys happy, Dunphy.