2018-04-20_REVISION - M1982090

• Permit No: M1982090
• IBM Index Class Name: REVISION
• Doc Date: 4/20/2018
• Doc Name: Adequacy Review Response
• From: Caldera Mineral Resources
• To: DRMS
• Email Name: THM
• Email Name: GRM
• Media Type: D
• Archive: No

Caldera Mineral Resources, LLC
P.O. Box 297 RECEIVED
Silverton,CO 81433
APR 2� 2
018
April 16, 2018 DMStON OF RECLAMATION
MININGAND SAFETY
VIA U.S.MAIL and EMAIL
Travis Marshall
Division of Reclamation,Mining and Safety
1313 Sherman Street,Room 215
Denver,CO 80203
Re: Camp Bird Mine,Permit M-1982-090,TR-06,Response to Adequacy Review
Dear Mr. Marshall,
This letter is Caldera Mineral Resources,LLC's(Caldera)response to the Division of Reclamation,Mining
and Safety's(Division)February 15 preliminary adequacy review letter regarding Technical Revision No.
6(TR-06)to the Camp Bird 112 Permit(No.M-1982-090).
In its letter, the Division requests estimates for cubic yards to be moved for grading, topsoil
volumes/sources, and dimensions of structures to be demolished. TR-06 does not involve any of those
activities and is only intended to address the application of hydromulch to the slopes of the modern tailings
that occur above the flood stage of the nearby creeks.
The hydromulch application is proposed to be applied to 2.45 acres at an estimated cost of$27,624 per acre,
for a total of$67,680. No costs for regrading,topsoil placement or structure demolition are included.
The work detailed in TR-06 is required by EPA as part of the on-going Camp Bird Removal Action(RA).
Since the area subject to TR-06 falls entirely within the active permit boundary, EPA is allowing Caldera
to address that area through the Division's administration of the active permit.
Caldera proposes increasing the Financial Warranty(FW)by$67,680,which would bring the total FW held
by the Division to$157,680. For background,the following are the bases of the$90,000 FW currently held
by the Division.
1. $25,000: After reclamation during summer of 2007,the Division approved SR-02 and reduced the
FW requirement to $15,599 on November 5, 2007. In response,the former operator maintained a
FW of $25,000. From 2007 through August 2012, the area within the permit boundary was
considered by the Division to be in final reclamation. According to the inspection report dated
August 29, 2011 the completed reclamation was stable, in conformance with the reclamation plan
and the Division encouraged the operator to pursue a reclamation liability release.
2. $50,000:TR-04 was approved by the Division on September 20,2012,allowing a limited scope of
activities at the site and the associated reclamation resulting from those activities, entailed
distributing 11,200 cubic yards of inert materials excavated from the settling pond. This volume is
adequate for 18" of cover over the 4.5 acres of disturbance allowed under TR-04. The operator
estimated costs of$47,388 for the earthwork and revegetation work, and Caldera provided an
additional$50,000 of FW to address those costs. The buildings,portal and pond constructed under