APPCOR13042

• Permit No: C2006085
• IBM Index Class Name: Application Correspondence
• Doc Date: 5/10/2007
• Doc Name: Adequacy Response Letter
• From: Environmental Alternatives Inc
• To: DRMS
• Media Type: D
• Archive: No

24. The Vegetation Map (Map 3) was prepared by Kent Crofts of IME Consulting
and reflects vegetation study of the proposed disturbed site will be forwazded to
Division upon receipt.
25. Please remove and discard current Exhibit J, the GEM Consulting vegetation
study performed in 1991. Kent Crofrs will be performing site sampling in May of
the proposed disturbed area. The report will be forwarded to the Division upon
receipt by Northfield. Permit text was edited on page 2.04-26.
26. This item is no longer relevant as a new vegetation study will be performed
during May and a replacement, current report will reflect vegetation at the
proposed disturbed location.
27. A representative from the Division of Wildlife (DOW) visited the site in January
2007 regazding the listed threatened and endangered species listed on the US Fish
and Wildlife websites. The DOW report is provided in Exhibit T and addresses
each species identified in the adequacy review. Permit text on pages 2.04-27 and
28 was edited.
28. Details of the vegetation pazameters to be collected and the techniques to be used
for the yeaz-3 vegetation monitoring were added to the permit on revised page
2.05.4-12.
29. Sampling methods and statistical demonstrations for years 9 and 10 vegetation
monitoring were added to the permit on revised page 2.05.4-13.
30. Augmented seeding methods during reclamation were removed from the permit
text on page 2.05.4-10.
31. The proposed seed mix has been modified according to the Division's
recommendation and reviewed by Kent Crofrs of IME Consulting. Permit text on
page 2.05.4-10, including Table 2.05.4-2, has been edited to reflect the proposed
seed mix and reduced mulching.
32. Excavation material generated during construction of the slope and shaft will be
incorporated into the fill during construction of the mine bench area. Northfield is
requesting approval to utilize the material as overburden, based on proposed
testing, and thus not create any mine waste bank areas within the bench fill. Based
on the lithology as determined at adjacent drill holes and information from local
mines that operated in the Vermejo formation, Northfield anticipates no
significant quantities of toxic or acid-forming materials in the excavation
material. To support this statement, Northfield is currently running overburden
geochemical analyses on core samples from the facilities area to be submitted to
the Division. Exhibit AI is reserved for the analytical data. Discussion of
proposed testing and utilization of excavation materials in the mine bench fill was
included in revised permit pages 2.05.3-30 thru 32.
33. Exhibit L contains complete and current baseline water quality information.
34. A hydrologic monitoring plan for the operation is provided in Exhibit AB.
35. Both Map 1 and Map 7 have been modified to include ground water structures,
permit boundary with angle of draw and existing buildings. In addition, the
projected mine workings were modified such that the resulting angle of draw lies
totally within the proposed permit boundary.
36. An updated list of all structures within and adjacent to the area potentially
affected by mining was added to the permit text on pages 2.05.6-11 and 12.
402 Valley Rd, Suite G, Canon City, CO 81212 , CO 81212
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Phone: [phone] • Cell: 719-429-8950