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. <br />STATE ~iiiiiiiiiiiiiiiiii <br />OF COLORADO <br />DIVISION OF MINERALS AND GEOLOGY <br />Department of Natural Resources <br />1313 Sherman 51., Room 215 <br /> <br />Denver, Colorado 80207 ~~ <br />Phone: (303) A66-3567 ~ <br />FAX: 1303) 8328106 <br /> DEPARTMENT OF <br /> NATURAL <br />December 12, 1994 RESOURCES <br />Ms. Ann Tatum Roy Rome <br />Goverror <br />c/o Law Offices of Jim Tatum and Associates. lames ~«hhea~ <br />8703 Bonhomme c.e~°"ye Direct°' <br />Houston, Texas 77074 "'"h'e' a. `°"ti <br /> Division Dvtttor <br />Re: Response to Letter of November 29, 1994 <br />Basin Resources, Inc.; The New Elk Miue, Permit No. C-81-012 <br />The Golden Eagle Mine, Permit No. C-81-013 <br />Dear Ms. Tatum: <br />On November 28, 1994, the Division received your letter dated November 29, 1994 regarding <br />concerns with the potential for spontaneous combustion of coal stockpiled at the Golden Eagle <br />and New Elk Mines. <br />The Division's September 13, 1993 letter to Basin Resources indicated that Dr. James Pendleton, <br />employed with the Division, believed that if the sulfur content of a coal is 0.25 percent or <br />greater, and its moisture content is over 10 percent, and oxygen were available to the coal, then a <br />potential for spontaneous combustion of that coal could exist. <br />Basin Resources has, as part of its permitting process, provided an analysis of the coal typically <br />mined from the Golden Eagle Mine. This analysis is referenced on page 2.04-6(a) of the Golden <br />Eagle permit document (a copy of this analysis is provided for your benefit). While the total <br />(pyritic, sulfate and organic) sulfur concentration is 0.46 percent, the moisture content is less <br />than one percent (0.78 percent). <br />While this geochemical analysis itself indicates a lack of potential for spontaneous combustion of <br />the Golden Eagle coal, the permiee has taken additional measures that further reduce this <br />potential. As described by Basin Resources in their November 1, 1993 letter to the Division <br />(copy enclosed), Basin compacts the coal stockpiles at the New Elk Mine with heavy equipment, <br />reducing the availability of oxygen to the coal. Further, Basin has sealed the stockpile situated <br />north of [he Purgatoire River with asurface-binding agent to control fugitive dust, further <br />reducing oxygen availability. <br />I[ should also be noted that stockpiling of raw and processed coal has occurred at these mines for <br />15 years without, to our knowledge, spontaneous combustion occurring. <br />