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Mr. Ary and Ms. Bellantoni
<br />Page 2
<br />October 7, 2013
<br />The following items must be addressed by the applicant in order to satisfy the requirements
<br />of C.R.S. 34- 32.5 -101 et seq. and the Mineral Rules and Regulations of the Mined Land
<br />Reclamation Board:
<br />APPLICATION
<br />This application form is adequate as submitted.
<br />6.4 SPECIFIC EXHIBIT REQUIREMENTS — REGULAR 112 OPERATIONS
<br />Rule 1.10.1(1) includes a provision that the Applicant is not required to submit exhibits
<br />as part of an amendment application that have not changed or would present new
<br />information with respect to the original application, or previous amendments. Item 16 on
<br />page 4 of the amendment application states only Exhibits C, D, E and F need to be
<br />updated and have been submitted. The discussion indicates the remaining Exhibits A, B,
<br />G, H, I, J, K, M, N, O, P, Q, R and S are consistent with the approved application. The
<br />Division concurs that Exhibits A, B, H, I, J, K and P likely won't require updates for this
<br />amendment application. However, we believe Exhibits G, L, M, N, O, Q and R require
<br />clarification, if not updates. The comments below are therefore limited to Exhibits C, D,
<br />E, F, G, L, M, N, O, Q, R and S.
<br />6.4.3 EXHIBIT C - Pre - mining and Mining Plan Map(s) of Affected Lands
<br />1. Rule 6.4.3(a) requires adjoining surface owners of record be labeled on submitted maps.
<br />Based on the comparison of information presented in Exhibit F and the information
<br />shown on Exhibit C in the approved application, at least some of the land owners have
<br />changed since the permit was originally approved. Please include updated surface
<br />owners on Exhibit C.
<br />2. Pursuant to Rule 6.4.3(c), the mine plan map should show the existing topography of the
<br />area with contour lines of sufficient detail to portray the direction and rate of slope of the
<br />affected land. As a minimum, please include contour lines for areas not yet disturbed as
<br />part of the mining process for comparison with the contours on the Reclamation Plan
<br />Map, Exhibit F.
<br />3. Rule 6.4.3(f) requires water information in conjunction with Exhibit G. The current
<br />substitute water supply plan approved by the Colorado Division of Water Resources
<br />limits groundwater exposure to: "5 acres of pond area, 0.3 acre of dewatering trenches,
<br />0.1 acre of collection area, and 0.1 acre of return trench" for a total of 5.5 acres of
<br />exposed ground water. In conjunction with information to be provided in an updated
<br />Exhibit G requested in Comment #17, please explain how the Operator intends to limit
<br />the exposed groundwater to 5.5 acres both during interim operations and final
<br />reclamation.
<br />4. Parcel 6 is not labeled on Exhibit C, Mine Plan Map as it is on Exhibit F, Reclamation
<br />Plan Map. Please use consistent labeling for phases and Parcels of both Exhibits.
<br />5. Arrows are shown only in Phase II pointing from west to east in the submitted Exhibit C
<br />Mine Plan Map as prepared by ASI. The Phase II area is shaded green. No explanation
<br />is provided for either of these features. Please include a legend explaining these two
<br />
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