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<br />MINED LAND RECLAMATION DIVISION
<br />Department of Natural Resources
<br />1313 Sherman St., Room 215
<br />Denver. CO 80203
<br />303 8663567
<br />FAx~303 832-8106
<br />June 29, 1992
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<br />Roy Romer.
<br />Governor
<br />Michael B. Long,
<br />Division Director
<br />Dr. W.D. Corley, Jr.
<br />The Corley Company
<br />P.0. Box 1821
<br />Colorado Springs, CO 80901
<br />RE: Diversion Ditch/Access Road, Citizen's Complaint, G.E.C. Minerals, The G.E.C.
<br />Strip Mine, West Pit, Permit C-81-037
<br />Dear Dr. Corley:
<br />The Division has proceeded in its investigation of your concerns about the diversion
<br />ditch/access road northeast of Sediment Pond D and the West Pit. We have reviewed
<br />photos borrowed from Energy Fuels Coal, Inc. These photos were taken on August 22,
<br />1985; December 31, 1986; January 2, 1988; January 4, 1989; June 29, 1990;
<br />December 27, 1990; and June 4, 1991.
<br />Your April 25, 1992 letter alleges that Harrison Western converted a diversion ditch
<br />into an access road in 1990. The Division sent a letter to you on May 27, 1992
<br />indicating that the maps in the Division's copy of the G.E.C. permit did not
<br />delineate any ditch in that location, although there was an access road in that area.
<br />The objective of our review of the E.F.C.I. photos was to identify if a ditch had
<br />been present prior to October, 1990, and if erosion following October, 1990, was
<br />exacerbated by Harrison Western's maintenance of the West Pit. The photos did not
<br />affirm that there was a ditch on the road. The photos did show a steady progression
<br />of erosion above and below the road between 1988 and 1991. Ravelling below the east
<br />leg of the road and a long gulley in Overburden Stockpile No. 2 first definitively
<br />appeared in the January 4, 1989, photo, suggesting that precipitation during the
<br />1988 calendar year was erosive at the site. The gullies above and below the road
<br />did not seem to multiply or grow significantly between June 29, 1990 and June 4,
<br />1991, the period in which Hdrri50n Western did their work.
<br />Comparison of the June 29, 1990 and December 27, 1990, photos did indicate that
<br />maintenance work had indeed occurred in the West Pit, as rock check dams and straw
<br />bales were visible on the December photo. In addition, vegetation along tie road
<br />appeared to have been removed, suggesting tha passage of some kind of blade. The
<br />June 4, 1991 photo further indicated that the southern portion of the road had been
<br />extended around the south side of the pond.
<br />In conclusion, minor road work was performed between June 29, 1990, and December 27,
<br />1990, on the approximately 500' long access road to the West Pit. The Division
<br />finds that Harrison Western's work did not appear to have materially exacerbated the
<br />erosion between the top of the overburden stockpile and the Magpie Creek Diversion.
<br />The grading of the road was not excessive in its accomodation of the movement of
<br />maintenance equipment into the West Pit on the extensively disturbed, unreclaimed
<br />site. Furthermore, as described in the Division's May 27, 1992 letter, there is
<br />inconclusive evidence that there was a ditch along the inside edge of the access
<br />road.
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