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• iii iiniiiiiiiii iii • <br />~ IATE OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman St., Raom 215 EwEp <br />Denver, Colorado 80?0) REC <br />Phone: 13031 866-]567 <br />FAX. (703) 8J2~8106 r~t~ <br />" q~ 1 2opp <br /> N0 <br />November 15, 2000 1Miperalsvod~eologY <br />~~ <br />DIVISION OF <br />MINERALS <br />GEOLOGY <br />R E C L A M A T I O N <br />MI NING•SAFETY <br />Divlalon n , ~ <br />Mr. Chris Nofsinger ' -'' <br />//~ R~II Owens <br />Nielsons, Inc. ~ ~ e_~_ Iq ~ / Governor <br />I : -, <br />P. Q. BOX 1660 - ~ ~ ' Greg E. 1Valcher <br />i': -" 4 ~ Esecwrve Dkeclor <br />Cortez, Colorado 81321 _ ~ ;', ~ C~i~_„~,_ ~~~ 2 <br />"~ Michael B. Long <br />Re: Craig Pit, Permit No. M-1976-027, Technical Revision No. 2 Third Adequacy Review Divsn~n Director <br />Dear Mr. Nofsinger <br />The Division has reviewed Nielsons Inc.'s November 13, 2000 response to DMG's second adequacy review <br />letter for your Technical Revision No. 2 (TR-002) application to the Craig Pit permit. A couple of items <br />remain to be adequately addressed before the Division can approve the TR-002 application. <br />Nielsons, Inc. must respond to this letter, by noon of November 17, 2000. Failure to respond adequately, <br />or submit a written request for extension of the decision due date, by noon of November 17, 2000 may <br />result in denial of this application. <br />Adeauacv Comments <br />The east highwall is shown, on Exhibit C-2 Phase 2, to be maintained at a 1 /2:1 slope though the <br />reclamation cost estimate calculates grade reduction costs for this highwall based on reducing a vertical <br />highwall to a 2:1 slope. Please revise either the map or the cost estimate so they are consistent. <br />The heights for the north, east and west highwalls are shown, on the application maps, to be in excess <br />of 50 feet and as high as 100 feet, though the reclamation plan states a depth of gravel up to 50 feet <br />and the reclamation cost estimate uses heights of 50 feet or less to calculate material volumes for <br />highwall reduction tasks. Please see the enclosed copy of the reclamation cost exhibit with penciled in <br />corrections for average highwall heights and material volumes that correspond to those tasks. The <br />penciled in calculations also include a reduced figure for volumes required if all highwalls are maintained <br />at a grade of 1 /2:1 instead of vertical. Please revise the mining and reclamation plans to specify the <br />highwall geometry that is consistent with the maps and specifies whether the highwalls will be mined <br />vertical, or ai 1 /2:1. Also, revise the reclamation cost exhibit to be consistent with the revised plans <br />and/or revised maps. <br />The volume of material needed to fill the center deep pit, the north highwall and the south highwall is <br />significantly more than the volume of overburden material that is available on site. The volume of <br />material necessary to fill the center pit, as shown on Exhibit C-1 is calculated at approximately 50,000 <br />c.y. The volume of material necessary to fill 450 feet of vertical north highwall, shown to be an <br />average of 80 feet in height, reducing it to a 2:1 grade, is calculated at 106,666 c.y. The volume of <br />material necessary to fill 350 feet of vertical south highwall, shown to be an average of 90 feet in <br />height, reducing it to a 2:1 grade, is calculated at 105,000 c.y. This results in a requirement of <br />261,666 c.y. of material needed for the proposed backfilling tasks. With an estimated 72,000 c.y. in <br />the southeast overburden stockpile, and an estimated 62,222 c.y. of in place overburden (average 10.5 <br />foot depth) in the unaffected areas of Phase 2, there appears to be 134,222 c.y. of overburden <br />available for backfilling. This results in a shortfall of approximately 127,444 c.y. of fill material. When <br />the fill volume calculations are based on an assumption that all highwalls are maintained at a 1 /2:1 <br />