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iii iuiuiiiiiu iii 999 STATE OF COLORADO DIVISION OF MINERALS AND GEOLOGY Department of Natural Resources 1313 Sherman 51., Room 215 Denver, Colorado 80203 Phone: (3031 8663567 FA%. (3031 832-8106 December 12, 1994 Ms. Ann Tatum c/o Law Offices of ]im Tatum and Associates 8703 Bonhomme Houston, Texas 77074 Re: Response to Letter of November 29, 1994 Basin Resources, Inc.; The New Elk Mine, Permit No. C-81-012 The Golden Eagle Mine, Permit No. C-81-013 1 / Dear Ms. Tatum: I~~ DEPARTMENT OF NATURAL RESOURCES Roy Romer Goverrgr lames S Lochhead E.eCUlrve DireC10~ mahael B. long Drvrsion Direao~ On November 28, 1994, the Division received your letter dated November 29, 1994 regarding concerns with the potential for spontaneous combustion of real stockpiled at the Golden Eagle and New Elk Mines. The Division's September 13, 1993 letter to Basin Resources indicated that Dr. James Pendleton, employed with the Division, believed that if the sulfur content of a coal is 0.25 percent or greater, and its moisture content is over 10 percent, and oxygen were available to the coal, then a potential for spontaneous combustion of that coal could exist. Basin Resources has, as part of its permitting process, provided an analysis of the coal typically mined from the Golden Eagle Mine. This analysis is referenced on page 2.04-6(a) of the Golden Eagle permit document (a copy of this analysis is provided for your benefit). While the total (pyritic, sulfate and organic) sulfur concentration is 0.46 percent, the moisture content is less than one percent (0.78 percent). While this geochemical analysis itself indicates a lack of potential for spontaneous combustion of the Golden Eagle coal, the permiee has taken additional measures that further reduce this potential. As described by Basin Resources in their November 1, 1993 letter to the Division (copy enclosed), Basin compacts the coal stockpiles at the New Elk Mine with heavy equipment, reducing the availability of oxygen to the coal. Further, Basin has sealed the stockpile situated north of the Purgatoire River with asurface-binding agent to control fugitive dust, further reducing oxygen availability. It should also be noted that stockpiling of raw and processed coal has occurred at these mines for 15 yeas without, to our knowledge, spontaneous combustion occurring.