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Re: Zorax post# 46389

Tuesday, 05/22/2012 7:04:11 PM

Tuesday, May 22, 2012 7:04:11 PM

Post# of 67010

but it did show where my layman's terms were pretty accurate

.

Accurate? Not by a long shot!
Your post describes the circumstances 180° from what it is in reality. You presented this in your original post:

A DRMS permit which has been pulled pending violations of compliance by the holder. Temporary status means review proceedings are active to reactivate or deny the permit.


That is not what this "Temporary Cessation" is about, nor is it in any stretch of the imagination close to what you presented in this last post..
"Temporary Cessation" is just what it says it is, a request or notification by the mining operation telling the state that there is an intent to stop work for more than 180 days and no longer than 5 years, with an option to extend that classification for an additional 5 years.

Here is what you failed to include: (omission in red)

.1.13 CESSATION OF OPERATIONS—TEMPORARY FOR ALL MINING OPERATIONS OR PERMANENT FOR IN SITU LEACH MINING OPERATIONS
1.13.1 General Provisions
(1) A permit granted pursuant to these Rules shall continue in effect as long as:
(a) an Operator continues to engage in the extraction of minerals and/or the mining operation and complies with the provisions of the Act; and
(b) mineral reserves are shown by the Operator to remain in the mining operation.

(2) The Board will consider all relevant testimony and facts related to a mining operation in its determination as to whether or not temporary cessation has occurred. The Board recognizes that no one factor is necessarily determinative, but that each determination will be based on site specific conditions. Factors to be included in the determination if a mine will be considered for temporary cessation, include, but are not limited to the following:
1.13.2 Indications of Temporary Cessation
(1) there are no personnel working at the site for one hundred eighty (180) consecutive days;
(2) there are only security personnel at the site;
(3) there are personnel other than security people at the site, but they are engaged i activities which can be described as maintenance or housekeeping, or related activity;
(4) there are personnel at the site, but they are engaged in activities which are n significantly moving the site towards completion of the mining operation. The Board wi judge these activities in relation to the size of the operation, the nature of the ore body an other facts;
(5) there is no sale or processing of material or movement of stockpiled material;
(6) there is only minimal or token excavation of mineral or other material; or
(7) mine development has ceased and mining has not recommenced.



The POW mill is a leaching operation, so this would apply in either case, permanent or temporary.
CGFI has recently asked for guidance from the DRMS regarding these rules and what circumstances would put them into the "Temporary Cessation" category. (That document is on the DRMS web site. The DRMS site is non responsive today, so you will have to look for it later, but the DRMS's response is basically a repetition of this section, if my memory is accurate.)
In respect to these rules, the "penalties" for non compliance do not exist unless the operation is deemed to be a TC first. Only then would penalties apply if the operator performs work on the site that exceeds those listed above.
What you are claiming to be fact is absolutely wrong.
Look on the DRMS web site as it becomes available. All those letters to Wallace Erickson, Environmental Compliance Specialist, from CGFI, were to insure that any work being conducted on the POW mill was within the scope of permitted tasks under the C&D order. Remember that letter with all those tasks listed and the word "proceed" repeated over and over?

Your words:

, it's been in temporary cessation for years before Cgi picked up the non compliance penalties. When updated, it should be clarified. Until then, the fees keep piling up.


What "non compliance penalties" are you referring to? There have been none in relation to the "Temporary Cessation" classification. There can't be. CGFI has not been classified "TC". And what "fees are piling up" as you put it? You are making unsubstantiated claims.

CGFI has, by your own admission, paid all fees associated with the permit as it stands today.
Your Post #45583, dated 5/7/12:

Active as in yearly fees are paid up to now.



The reason for classifying an operation as "TC" is to insure that environmental precautions and abatement procedures are performed during the cessation period. Since, as you have pointed out so many times, no production is being done since 2008, how can there be any cessation of work?

Your stated logic is faulty. Your claims that the fees "keep piling up" are by your own post's content, wrong, or a gross exaggeration at best.

I submit that CGFI is investigating, with due diligence, what the removal of the C&D order's effect will have on its permit's standing, and what actions will be necessary to fulfill the requirements regarding a possible extended period before the mill is in operation. That is just a prudent thing to do.

I submit that your interpretation is just an erroneous opinion that has no valid research behind it.
You have presented a "guess" with specious proof.



Don't take my word for it, Do your own research! Then you will know it's true!

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