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Extract to table / state-permit-coordination-memo.docx
state-permit-coordination-memo.docx
Parties
Torchlight Mining Corp
Harkness LLP
Weiss LLP
Dates
February 8, 2025
February 19, 2025
March 21, 2025
May 15, 2025
June 14, 2025
February 14, 2025
December 31, 2019
November 1, 2024
February 10, 2025
December 14, 2025
Amounts
$5.8
$10,000
$25,000
$5.5
$245.0
$165.0
$80.0
$42.8
$34.1
$7.9
Obligations
Ridgecrest Mine Holdings, LLC, and Bonanza Creek Mining, LLC — must maintain independent compliance with all state environmental permits
This memorandum provides a comprehensive overview of the three-state regulatory architecture applicable to TMC's operations, identifying the specific state permit obligations at each site, the intersections and potential conflicts with the Consent Decree, and the affirmative steps TMC and its counsel must take to coordinate federal and state compliance
In addition to dissolved copper, the Ridgecrest discharge contains elevated concentrations of other contaminants of concern that must be addressed in any MPDES permit modification: • Sulfate: Average discharge concentration of 3,400 mg/L
The current MPDES permit is scheduled for renewal, and the timing of any permit modification or renewal application must be carefully coordinated with the Consent Decree remedy milestones
To the extent that the corrective measures study identifies the need for upgraded wastewater treatment systems, additional monitoring points, or revised effluent limits, these changes must be reflected in the MPDES permit through a formal permit modification process
With the cessation of active mining on December 31, 2019, this permit must be amended or converted to a reclamation-only permit that reflects the facility's current closure and reclamation status