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,'--~ DIVISION OF MINERALS AND GEOLOGY Depanment of Natural Resources 1313 Sherman St., Room 215 Denver, CO 80203 Phone: (3031 866-3567 FAX: (301)832-8106 November 2, 1995 Brian Kimmel Southwest Land Services, Inc. P.O. Boz 2673 II I' I~' ~I I ~I "I~'II 999 F COLORADO ~~,~a 1~ -~r~ UF~pLy. OF'~OCp '`~' b ~r ii •'~'~ o Noy Fonrtr Gnvemw raichael B. Long Divivnn ^ire~lo~ Durango, Colorado 31302 RE: Gardner Pit No. 2A, Permi[ No. M-90-025, Conversion Application No. i (CN-001) 2nd Adequacy Review Dear Mr. Kimmel: On November 1, 1995, the Division received your response to our September 14, 1995 adequacy review of the 112 conversion applicatlon for the Gardner Pit No. 2A. Upon review of the responses, the following additional concerns were identified: If haul roads will not involve construction, but wilt generally be designated areas on the pit floor, then the Division will not bond for reclamation of these roads other than ripping before topsoil placement Due to the lack of information provided concerning these roads, the Division will calculate the cost for ripping of haul roads based on an assumed mazimum of 2500 feet ]n length by 25 feet In width. If Blasting and Mining does not agree with these assumptions, please clarify their intentlons as soon as possible and indicate, on the appropriate maps, where the roads will be located 2. Please revise the reclamation map to remove the indication that a berm wl[I remain on the areas where the pit wiU actuallq daylight. Also, the incorrect final elevations indicated on The map wiU need to be revised. The ink pen eorrectiens on the location map, submitted with your November 1 submittal, vutll be accepted. However, the revisions required above will need to be corrected by erasing the tncorrect information and replacing it (if necessary) with the correct information. 3. The information provided on the backfiiDng methods is very vague. Without specifics, the Division must calculate the reclamation bond on worst case scenario specifications. The permit application specifies that generally, overburden will be direct hauled and placed behind the active operation and progress in the direction of mining. The backfilDng will be calculated assuming a 700 foot by 17.foot highwaD backftlled to a 4:1 slope. The calculation will assume that material will be placed 75 percent from Ute toe of the highwaD upwards and 25 percent from the top down. Unless areas can be designated on the map for cut and fill highwall reduction, this can not be figured into the calculation. Again, please provide clear, accurate and complete information regarding backfilDng, as soon as possible, if the assumptions made bq The Division are not acceptable to the operator. 4. Overburden replacement will also be calculated on the assumption that 75 percent is direct hauled to a location behind the active operation and 25 percent Is stockpiled in front and to We