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STATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY ~ <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />November 5, 2004 /~ <br />Mr. Dick White <br />Cotter Corporation ~ <br />28151 DD Road <br />Nucla, Colorado 81424 <br />RE: SM-18 Mine, Permit No. M-1978-116, Amendment No. <br />Dear Mr. White: <br />1 Third Adequacy Review `'~ <br />COLORADO <br />DIVISION OF <br />MIN SRALS <br />GEOLOGY <br />0.ECLAMATION•MIN ING <br />SAFETY•SCIENCE <br />Bill Owens <br />Governor <br />Russell George <br />Executive Director <br />Ronald W. Cattany <br />Division Director <br />Natural Resource Trustee <br />The Division of Minerals and Geology (DMG) completed review of Cotter Corporation's (Cotter) response to the <br />second adequacy review of your application for Amendment No. 1 (AM-01) to Permit No. M-1978-116 for the <br />SM-18 Mine. The application cannot be approved until these last few remaining issues are adequately <br />addressed. Please submit a response to the following issues as soon as possible, but no later than 1:00 P.M. <br />November 8, 2004. If your response, or an extension request, are not received by that date and time this <br />application may be denied. <br />ADEQUACY ISSUES <br />4. According to Tom Schreiner, DMG hydrologist, the overall ditch, impoundment, and riprap sizing looks <br />adequate. However, there are 3 items that need to be addressed: <br />a) The riprap designs and representative cross sections should specify the thickness of riprap application; <br />b) the riprap will need to be installed throughout the entire width of the channel rather than a portion of it; <br />c) the drainage channels will need to be over-excavated in locations to receive riprap so that the desired <br />storage capacity will still be available after the riprap has been installed, i.e.: the channels should be 2 feet <br />deep following riprap installation. DMG also suggests that Cotter install a filter bed material such as pea <br />gravel or a synthetic fabric, and "key in" the riprap for best results. <br />7. The commitment to perform the required waste rock and ore sampling and analyses is acceptable. <br />Please be aware that analyses results that indicate the presence of acid or toxic forming materials <br />that may result in adverse impacts to the environment, human health or wildlife could result in <br />classification of Permit M-1978-116 as a Designated Mining Operation per Rule 7, requiring <br />submittal of a Environmental Protection Plan in compliance with Rule 6.4.20. <br />If you need additional information, please contact me at the Division of Minerals and Geology, Grand <br />Junction Field Office, 101 South Third Street, Room 301, Grand Junction, Colorado 81501, telephone no. <br />970-243-6368. <br />Sincerely, <br />Steve S. Shuey <br />Environmental Protection Specialist <br />cc: Ed Cotter - SM Stoller/DOE <br />Harry Posey, DMG <br />Office of Office of Colorado <br />