GENERAL32754

• Permit No: M1984014
• IBM Index Class Name: General Documents
• Doc Date: 6/12/2006
• Doc Name: Appeal of DMO Status
• From: Cotter Corp.
• To: DMG
• Permit Index Doc Type: DMO
• Media Type: D
• Archive: No

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Received
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firend Junction Field Office
Division of Minerals & Geology
June 7, 2006
Russ Means
~olorado Divisiori"of Nlin`erals and'Geology~
Grand Junction Field Office
101 S. Third St, Room 301
Grand Junction, Colorad~o~~!81501
RE: Permit No. 1984-DL'4, JD=g'Mi~ne, Appeal of O Statu~
'----- --
Mr. Means:
Cotter Corporation is submitting this letter to list the proposed measures of gathering
additional information to support Cotter's appeal of the Division's determination that the
JD-8 Mine is a Designated Mining Operation.
In the Division's letter to Cotter (March 9, 2006), the Division stated that "Cotter may
elect to gather additional groundwater information and detailed information on the non-
transmissiveness of the faults, which would support the modeling."Afield meeting was
held May 2, 2006 between DMG personnel (Russ Means and Kate Pickford), Cotter
(Glen Williams and Dick White), and Cotter's consulting hydrologist (Peter Kearl) to
discuss these proposed measures, which are summarized below.
Since the report of the modeling was submitted, Cotter has investigated the mine located
beneath the northern edge of the JD-8 Mine waste rock pile. This mine is in the down-
dropped fault block relative to the JD-8 Mine. The workings of that mine are nearly 200
feet below the base of the JD-8 waste rock dump and terminate at, or very near the fault,
The mine is completely dry. Peter Kearl will submit a written report explaining how
faults act as capillary barriers in the unsaturated zone. Cotter will also submit a more
detailed geologic map and cross-sections showing the relationship of the waste rock
dump to the fault, the lower mine workings, and estimated water table.
The results of the modeling suggest that it could take up to 1,000 years for water to travel
from the waste dump to the water table, if it is 400 feet below. Therefore, rather than a
monitor well in the aquifer, Cotter proposes a soil water sampler (lysimeter) be installed.
It will be near, and on the down-gradient side of the waste rock dump, while still
allowing for dump expansion, Approximate locations were discussed with DMG during
the field meeting. This will serve as a timely sampling system showing the amount and
quality of water percolating through the dump material.
Cotter Corporation -West Slope Operations
P.O. Box 700, 28151 DD Road, Nucla, CO 81424 USA
Telephone [phone]
Fax [phone]