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~, .: <br /> <br />Renver,POmi No C-1981-022 OxbowMining.LLCa'"e~ct~1atl"~anaGe°`o9v <br />Responses to CDMG Februarv 27 2006 Adeguacv Review for MR-76. <br />March 7, 2006 <br />Mr. James Stark R~~~~v~® <br />Environmental Protection Specialist f~ <br />Colorado Division of Minerals and Geology . <br />~'t006 <br />1313 Sherman Street, Room 215 ~ <br />MAR <br />Dear Mr. Stark: <br />Oxbow Mining, LLC (OMLLC) received the Division's February 27, 2006 Adequacy review for <br />MR-76 yesterday, March 6, 2006. The purpose of this letter is to provide a response to the <br />Division's concerns. <br />1. Hydrology Monitoring Plan -- PAP Volume 12, Exhibit 2.05-E7 has been modified to 1) <br />include reference to the two B seam water transfer wells, 2) included reference to monitoring of <br />metered flows, 3) include reference to AHR reporting of annual transferred water in gallons per <br />year and 4) removal of reference to the sealed B-6 well. <br />3.. OMLLC is unaware of any DMG Rule language requiring that all work performed and <br />completed on the site be included in the overall liability. <br />OML~C~isR.tiowever,'aware of Rule 3.02.2(1) Determination of Bond Amount which clearly <br />iristructs the Division to calculate a pertormance bond "sufficient to assure the completion of the <br />reclamation work if the work had to be performed by the Board". Further, the regulations state <br />the amount required for the band shall reflect the probable difficulty of reclamation. In <br />determining the cost estimate, the regulations clearly require the Division to look at the work that <br />needs to completed in the future, not the work that has already been completed in the past. <br />OMLLC has demonstrated that the subject boreholes are sealed and would require no further <br />action by the Division. We believe the straight forward language of the cited Regulations would <br />not allow the Division to knowingly include borehole sealing in the cost estimate for boreholes <br />already sealed. , <br />Recognizing the Division has indicated it intends to use the $9,180.00 estimate, OMLLC <br />disagrees with the overall premise upon which portions of this cost determination is made. To <br />move the issue forward, however, OMLLC will agree to the proposed amount. <br />Please contact me at (970) 929-5806 if you have questions or require further,information. <br />Sincerely, <br />Envirorimerital~Coordihator' ' <br />Xc: 'Jim Cooper.(OMLLC) , <br />Files ' <br />3737 Hwy 133 P.O. Box 535 Somerset, Colorado 81434 USA <br />TEL (970) 929-5122 FAX (970) 929-5177 <br />