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<br />indicates that this pile needs to be revegetated. Telluride gravel must take adequate measures to <br />establish anon-weedy vegetative stand on this stockpile. Suggested measures include loosening <br />the soil surface seeding and mulching. Fertilizer applications may also be necessary. The <br />correction date will be extended to November 1, 2000. <br />Telluride Gravel is apparently confused about the details surrounding Notice of Violation M-93-017 <br />that was issued in 1993. The violation was issued because Telluride Gravel had, in their permit <br />application, failed to state all owners of the affected land and the substance to be mined and to <br />secure right of entry to conduct mining operations on all lands within the designated affected area <br />for the Alexander Pit. This area is within the Alexander Pit permit area and is therefore under the <br />jurisdiction of the Division of Minerals and Geology. Any mining related activities conducted <br />within the approved permit area, that are not part of the approved mining and reclamation plans, <br />must first be incorporated into the permit by means of a revision to the permit. <br />The Division does not understand how Telluride Gravel could have been unaware of the Division's <br />position and requirements regarding the area of violation where mining occurred on USFS property <br />within the approved permit boundary. This was made very clear in the original Cease and Desist <br />Order issued by the Mined Land Reclamation Board, the revised Board Orders (issued because of <br />the delay in securing agreements with the USFS), several letters from the Division, and both the <br />1997 and 2000 inspection reports issued by the Division. <br />The last revision to the Board Order was issued at the October 20, 1993 meeting of the Mined <br />Land Reclamation Board and ordered Telluride Gravel to report to the Board within 30 days of <br />receiving necessary Forest Service and Corps of Engineers permits allowing use or reclamation of <br />the Forest Service Lands disturbed by the mining operation so further corrective actions could be <br />taken by the Board. <br />The Division recognizes that the USFS and the Corps of Engineers did not issue permits for the <br />reclamation work performed on this area. However, it appears that this remediation work has <br />already been performed, so this matter has been scheduled for a formal public hearing before the <br />Mined Land Reclamation Board to address corrective actions and civil penalties associated with <br />Notice of Violation M-93-017. The hearing will be held at the December 73-14, 2000 meeting of <br />Board in Room 318 of 1313 Sherman Street, Denver, Colorado starting at 9:00 a.m. or as soon <br />thereafter as the issue can be heard. <br />It is highly recommended that Telluride Gravel attend this hearing and document what reclamation <br />measures have been taken on the USFS property and how those measures correspond to the <br />currently approved reclamation plan. Also, written documentation of USFS and Corps of <br />Engineers approval of the reclamation measures should be provided. <br />If you need additional information, please contact me at the Division of Minerals and Geology, <br />Durango Field Office, 701 Camino Del Rio, Room 125, Durango, Colorado 81301, telephone no. <br />970-247-5062. <br />Sincerely, <br />i~[~~ V~ <br />Steve S. Shuey <br />Environmental Protection Specialist <br />