2004-11-02_REVISION - M1977129

• Permit No: M1977129
• IBM Index Class Name: Revision
• Doc Date: 11/2/2004
• Doc Name: Preliminary Adequacy Review
• From: DMG
• To: Whitewater Building Materials
• Type & Sequence: TR2
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman St., Room 2t6
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
November 2, 2004 `~
Mr. Edward M. Gardner
Whitewater Building Materials Corporation
P. O. Box 1769
Grand Junction, Colorado B1502
COLORADO
DIVISION OF
MINERALS
GEOLOGY
RECLAMATION•MINING
SAFETY•SCIENCE
Bill Owens
Governor
Russell George
Executive Director
Ronald W. Cottony
Division Director
Natural Resource Trustee
I/ :~ ~~
RE: Whitewater Pit 500, Permit No. M-1977-129, Technical Revision No. 2 Preliminary Adequacy
Review
Dear Mr. Gardner:
DMG completed the preliminary adequacy review of your application for Technical Revision No. 2 (TR-02)
to Permit No. M-1977-129 for the Whitewater Pit 500. The application cannot be approved until the
following issues are adequately addressed. Please submit a response to the following issues as soon as
possible, but no later than November 12, 2004 so the decision due date set for November 19, 2004 can
be met. If you cannot respond by November 12, 2004 please submit a written request for extension of
the decision date. If your response, or an extension request, are not received by November 12, 2004 this
application may be denied.
ADEQUACY ISSUES
1. The proposal to revegetate the cattle feeding area in Stage X and Y makes sense, now that the
area is federal property and will no longer be used for cattle feeding. The proposed revised
efforts to revegetate Stage X and Y, including the pocking and updating of the seed mix, as
well as installation of a fence to keep cattle off the revegetation areas is a proactive measure
that should result in greater success than has been realized by the past revegetation efforts.
However, as explained to the BLM in previous conversations, and consistent with DMG policy,
the Mined land Reclamation Act and the Construction Materials Rules and Regulations, a
revision cannot be approved that does not provide for revegetation of all disturbed areas unless
the lack of vegetation on these areas is consistent with the post-mining land use
(recreation/wildlife habitat) and will not jeopardize the engineering and erosional stability of
those areas. In the proposed revision, the majority of the pond embankments are designated
to remain unseeded. This proposal cannot be approved because these areas are required to be
revegetated. These slopes are subject to erosion and weed infestation if not adequately
vegetated.
The permit may be revised to include a perimeter road around the Phase 1 lake, which would
be consistent with the recreation designation of the post-mining land use, but the slopes must
be revegetated.
Office of Office of Colorado