Fabled Silver Gold Corp T.FCO

RE: Of Arsenic and ore

[pcnisbet]

Rio Bevill, not Beville. It’s good that you are finally coming to grips with your earlier errors. Must have been a very intense googling session. Earlier you had inferred to this board that there were extreme concerns about mine placement of waste rock, milled tails and the rest at the mine site and suggested you understood that because you were an expert in Bevill and RCRA. Great that you now acknowledge to this assembled group that the tails and the other materials from the mine site are not a RCRA concern. So yes, there is no need as you had earlier stated to ship water treatment sludges to special facilities, they can be disposed of underground, as Noranda does at the Blackbird Mine or as Barrick does at Carlin. Similarly, their tails design does not need to meet any sort of Bevill requirements, nor do non-ore headings un-milled rocks or any of the rest. So Bevill and RCRA are not an issue in the permit stream for the MINE site, which is the issue at hand, the permitting of the mine. The USFS and the JRP team will not be considering any issues not related directly to the mine site, which includes your supposed concern with Montana blocking interstate commerce. Hence you floated a major red herring. Further, you bring up a separate issue of the refinery processing stream and the potential for RCRA coming to play at that site. That is a separate issue from the mine and does not impact the EIS at the mine. They do not need to explain in the EIS how they intend to handle their concentrates and do not need to explain to you or the groups that you represent how they intend to handle those issues. For the purposes of the Mine EIS, all they need do is say they will be producing a concentrate and shipping it off site. You have suggested to this board that lack of information on Bevill and the final disposal of the materials from concentrates were potential sticking points in the EIS process and that they would or could result in Lawsuits and other hindrances to permitting. Now it should be evident that they are not indeed involved in the mine permit process for the mine and what arsenic containing materials that are generated at the mine site can indeed be disposed of in the manner I have previously suggested and then stored back underground with no problem. Since that is all legal and within the venue of existing law and practiced commonly through the whole of the minerals industry, guess there is no lawsuit potential, now is there. On the seperate issue of RCRA compliance at the refinery, there is no requirement with that regard to follow the process used in NEPA and conduct EIS processes. What they proces at that facility and the requirements that they have for the site is a matter for dicussion with the EPA and is not related to any sort of public pressure tactics that green advocates may chose to bring. But let's assume that they declare the final waste stream at the refinery a RCRA material that needs disposal at a facility. The per ton disposal costs of the final waste stream is a small fraction of the value of the cobalt, a managable and reasonable cost of doing business. It has nothing to do with the mine, hence is not a mine killer. It is solely an issue of the refinery and is not a killer with respect to producing either cobalt metal or cobalt chemicals. They just need to discuss and negotiate their disposal plans with the EPA and do not need to consult you or any environemtnal group in the process. That makes the RCRA and Bevill issues at the refinery a red herring, just as your earlier attempt to suggest that mine wastes at the MINE site were RCRA controlled. I am really glad that we could clear up your obvious lack of understanding of the process and the law as it relates to minerals activities at FCO's planned mine site and refinery area. Now all you need to do is google Interstate Commerce and maybe we can put that red herring to bed as well.