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