REV97571 - Laserfiche WebLink

Home Browse Search

STATE OF COL~,<.~,~ MINED LAND RECLAMATION DIVISION Department of Natural Resources 1313 Sherman St., Room 21 S Denver, CO 80203 303 866-3567 Fa X: 303 832-8106 May 14, 1991 Mr. Karl Koehler Cyprus Orchard Valley Coal Co. P.0. Box 1299 Paonia, CO 81428 Re: Incidental Bouncary Revision/Alluvial Valley Floor Designation, Orchard Yalley Mine, Permit C-81-038 Dear Mr. Koehler: O_F' ~~r0 E. 9,~ He ~~`$ .;~y ~ re 96 ~ Roy Romer, Governor Fred R. Banta, Division Drrector The Division has received and reviewed the letter dated Nay 2, 1991, It contains information, and a reiteration of the rationale that COVCC believes supports the contention that the lands surrounding the Orchard Valley loadout, and the land on which the loadout is located, are incorrectly designated as part of an Alluvial Yalley Floor (AYF). COVCC correctly states in the letter the criteria upon which the Division must base its decisions regarding whether to find that an AVF exists or does not exist. It is also apparent that the paragraph in the 1983 and subsequent findings document that outline the facts on which the Division based its AVF finding is unclear as to the specific designation of the deposits on which the area in question lies. We believe that this confusion in the findings aocuments stems from ambiguity contained in the Geo-Hydro Phase I study and the subsequent Phase II study. While the conclusions in this study may state that "the area cannot be classified as an unconsolidated streamlaid deposit " the geomorphic units descriptions contained in Appendix A seem to state the opposite. The "fine-grained slope outwash (pediment) deposits ... are generally loosely consolidated material of fluvial and coltwial origin .. " The "coarse-grained slopes outwash (pediment) deposits are similar in genesis to the above material, but are derived from different source rocks." Thus it would seem that the fl uvial nature of these deposits is given in the Phase I study; therefore, we contend that the deposits in question are indeed streamlaid and can be classified as such. Further, it is significant to note that no objection to the AVF designation was raised in 1983 and a Phase II study was initiated. This Phase II study produced hydrogeologic cross sections of the area using drill hole data from monitoring wells MW-1, MW-2, and MW-3. Data from two test pits in the alluvial gravels of the North Fork Gunnison River were also used.