2007-05-29_REVISION - M1982020

• Permit No: M1982020
• IBM Index Class Name: Revision
• Doc Date: 5/29/2007
• Doc Name: Succession of Operator Request
• From: DRMS
• To: Melvin & Robert Gydesen
• Type & Sequence: SO1
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
May 29, 2007 ~
Melvin Gydesen
Robert Gydesen
502 S. Wisconsin St.
Gunnison, Colorado 81230
COLORADO
DIVISION O F

C~+~IVED RECLAMATION
MINING
R
L,V E

MAY 31 ZU01 SAF
TY
Division of Reclamation, Bill Owens
Mining and Safety cnvernor
Russell George
Executive Director
Ronald W. Cottony
Division Director
Natural Resource Trustee

v ~ V
Re: Lucky Strike Lode, Permit No. M-1982-020, Succession of Operator (SO) Request and Outstanding Issues.
Dear Mr. Gydesen;
On February 5th, 2007, the Division of Reclamation, Mining and Safety received a request for a Succession ofOperator
for the above referenced permit. Weather and access issues prevented staff from moving forward on the application
until mid May. As part of the SO request, the applicant chose Option A which requires the Division to recalculate the
reclamation liability for the site. The Division at this time cannot move forward with that request until two issues are
resolved because they directly affect the recalculation of the reclamation liability. The permit Sle indicates that these
issues are outstanding from the September, 2006 inspection. In the case of custom milling, the issue is noted as far
back as May of 2004.
Lucky Strike Lode submitted an assay report and a Wyoming Certificate of Organization to address these issues on
December 4'", 2006. Both documents are insufficient to address the issues. The assay may determine the constituents
of the rock but does not address the long term impacts of such material to the environment through exposure to the
elements. The Division must have proof of Colorado organization from the Colorado Secretary of State. Concurrently,
the SO applicant is not part of the documentation submitted.
Lucky Strike Lode must address the outstanding issues in order for a reclamation liability estimate to accomplish and
approval of the Succession of Operator.
1) The Division must have clear documentation showing who is in control of any and all mines bringing ore to the
mill. Alternatively, if the site is to be leased to a different mining company, then the Division needs a copy of
the lease between the two parties. If not already provided, documentation of control of any mines bringing ore
to the site by the lessee will be required as well. Without this documentation, the Division mayhave no choice
but to submit the information to Gunnison County and the Colorado Department of Health for possible Custom
Mil] Status consideration due to the fact, that by definition, the site appears to be one.
2) The Division has requested geo-chemical analysis of any ores generated at the site and those being imported for
processing. Geo-chemical analysis of the tailings being pumped to the tailings pond is required as well. The
Division received assay reports which are insufficient to determine the possible long term environmental
impacts. The analysis must be done by a state certified laboratory and by approved EPA protocol such as a
Synthetic Precipitation Leachate Process (SPLP) or the Nevada Meteoric Test (Nevada Test). For specific
analyzes and a discussion on the best procedure, it would be best to contact the Division's Geo-Chemist, David
Bird at 303.866.3927. Without the geo-chemical analysis, the Division cannot accurately determine what
method of reclamation is required and calculate the reclamation bond for approval of the SO.
Office of Office of
Mined Land Reclamation Active and Inactive Mines