2002-03-06_REVISION - M1985129 (3)

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STATE OF COLORADO DIVISION OF MINERALS AND GEOLOGY Department of Natural Resources 1313 Sherman SL, Room 215 Denver, Colorado 80203 Phone: (303) 866-3567 FAX: (303)832-8106 Mazch 6, 2002 Mr. Todd Ramer Elbert County 215 Comanche St, Box 597 Kiowa, CO 80117 Re: Second Adequacy Letter, Amendment #I Application, Elbert County Pit, M-1985-129 Dear Mr. Ramer: DIVISION Of MINERALS GEOLOGY RECLAMATION MINING•SAFETY Bill Owens Governor Greg E. Walther Executive Director Michael B. long Division Director The Division completed a review of your response to the Division's first adequacy letter regazding the expansion of the existing pernut azea. As noted in the first adequacy letter, the existing permit area is being expanded to 71.8 acres. However, as noted, the proposed expansion assumes that the original pernTit azea contained 22.2 acres. According to 1985 permit documents, the area to be mined contained 22.467 acres. After adding in the access road, the permit area increased to 24 acres. There are no documents in the file (release requests, etc.) that would .- indicate areduction in the permit size ever occurred; since 1985. So, therefore, the size of the expanded permit area should be 73.6 acres, if you are adding 49.6 acres (49.6 acres plus 24 acres). You did not address this concern in your response. You need to determine the exact acreage of the proposed expanded permit azea and revise the application form, if necessary, to reflect the correct amount of acreage in the proposed permit azea. The DMG attempted to calculate the access road acreage but was unable to because the map scale is incorrect. It appeazs, the map scale should be 1" = 184 feet instead of 1" = 100 feet. Excluding the access road, the DMG's estimate of the proposed expanded acreage is 72.31 acres. The difference between the DMG's estimate and your estimate may have occurred because of a possible error in the proposed boundazy. The east-west distance on the north end of the proposed boundary is 2,275 feet (300'+1,500'+475'). The east-west distance on the south end of the delineated boundary is 2,250 feet. If 2,250 feet is the correct east-west distance, the acreage (excluding the access road) is 71.8 acres. Given the access road is wider than the approved 30 foot width and, also, the access road is not as long as originally approved (921 feet originally), the estimated access road acreage is 0.76 acres (663'X50'). If the 71.8 acre calculation is correct, and the 0.76 acre estimate is correct, the total acreage of the proposed expansion is 72.56 acres. If the east-west distance of the permit boundazy is 2,275 feet, the pemut acreage amounts to 73.07 acres (72.31+.76). This problem needs to be addressed. The maps need to reflect accurate permit boundary dimensions and the application forms need to accurately show the size of the permitted acreage. Also,the map scales need to be accurate. Your response to Rule 6.2 was adequate except for a couple of items. You did not include separate maps for Exhibit B and ExhibitC (which is okay since the map title states that it is used for both exhibits). However, the map title states that the map represents Exhibit B and Exhibit D. This should be Exhibit C not Exhibit D. You did not submit a map for Exhibit F (Reclamation