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._~ ``--~ ce cow ~~ ~`.% ~ '~ N1 'f i\f, ~ w i i ~4' ' /876 s RlcharrJ D. Lamm Gavemor iii iiiiiiiiniu iii 999 DEPARTMENT OF NATURAL RESOURCES David H. Gstches. Eaxutive Director P~!llds=® ~611~J~ RECLARItAT1ON DIyISIOfV DAVID C. SHELTON, Dlteetor April 18, 1984 Mr. Steve Layton GEC Minerals, Inc. P.0. Box 263 Independence, Kansas 67301 Ei(HIRIT 37 Re: Analysis of GEC Reclamation Plan and Timetable; April 11, 1984 Dear Mr. Layton: I have reviewed the plan submitted on behalf of GEC Minerals, Inc. and found that it does not satisfy the reclamation obligations for the GEC Strip Mine. In general, the plan is vague, does not address reclamation of all areas, and does not contain a schedule that will satisfy GEC's reclamation obligations in a timely manner. If these deficiencies are not corrected by April 25, 1984, I will report to the Board that the plan does not satisfy GEC's reclamation obligations and recommend forfeiture of the performance bonds. The specific deficiencies I've identified are: 1. GEC's plan calls for delaying reclamation until at least October, 1984. This is not satisfactory for several reasons, First, neither the law nor Permit C-037-81 contemplate delayed reclamation, ie.: reclamation must occur immediately after completion of mining. Second, a delay until October would mean missing most of the 1984 construction season. This would mean that full scale reclamation probably would not begin until the spring of 1985. 2. GEC's plan calls for spending ;5,000 - ;10,000 per month on reclamation of the site. This translates into about 5 years before backfilling and grading would be complete. Again, this does not satisfy the legal requirement to reclaim contemporaneously nor does it satisfy the obligations of Permit C-037-81. Exhibit 23, Attachment C of Permit C-037-81 call for completion of backfilling and grading of the East and West pits within an 18 month period. GEC's plan should replicate the schedule in the permit, 3. GEC's plan contains general references to the reduction of stockpile No. 1 to a more stable configuration. Stockpile No. 1 must be reduced to the post-mining topography shown on Map 23 for Permit C-037-81. This will require removal of a significant amount of material for placement in the West pit. 423 Centennial Building, 1313 Sherman Street Denver, Colorado 80203 Tel. (30~) 866.3567