2008-09-22_REVISION - M1980244

• Permit No: M1980244
• IBM Index Class Name: REVISION
• Doc Date: 9/22/2008
• Doc Name: Review of Surface Mine Slope Design
• From: DRMS-acs
• To: DRMS-bmk
• Type & Sequence: AM9
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
Denver, Colorado 80203
Phone: [phone]
FAX: [phone]
DATE: September 22, 2008
TO: Berhan Keffelew '
FROM: Allen Sorenson
COLORADO
D IV IS I ON OF
RECLAMATION
MINING
SAFETY
Bill Ritter, Jr.
Governor
Harris D. Sherman
Executive Director
Ronald W. Cattany
Division Director
Natural Resource Trustee
RE: Review of Surface-Mine Slope Design, Cripp,!?-Creek and Victor Gold, Cresson Project,
Amendment No.. AM-09, Permit No. M-1980-244
The Division of Reclamation, Mining, and Safety (DRMS) engineering staff has reviewed the Surface Mine Slope
Design submitted as appendix 5 to volume IV of the AM-09 application. DRMS has also reviewed other potions of
AM-09 where mine slope designs are described and the drawings where the mine slopes are depicted. Contrary to
the statements in the September 18, 2008 Applicant's response to adequacy review, is discussed in considerable
detail in the application that in order for the rock slopes described in AM-09 to be stable, specialized blasting to
create final pit walls is required. See particularly section 4.1 of appendix 5 to volume IV of the AM-09 application.
This specialized blasting is inefficient for open pit production, so it is only employed at the final blast to create the
outside extent of any of the pit walls. If the Operator were to default at some interim point in the mine plan and
DRMS were to reclaim the mine pits under bond forfeiture, substantial amounts of specialized blasting may be
required to stabilize mine slopes that have been subject to production blasting, and where final reclamation blasting
had not yet occurred. There are no costs dedicated to this required reclamation blasting in the cost estimates
provided by the Applicant. An estimate of these costs must be provided for DRMS review. The estimate must
consider the point in the mine plan where the greatest surface area of mine slope would require reclamation
blasting, which is not necessarily at the point of full mine out of the pits. If the Applicant wants DRMS to consider
reclamation blasting completed concurrently with the mine pits reaching the pit limits, then a plan for concurrent
reclamation blasting that will be enforceable under the terms of the permit must be provided. If the Applicant
wants the DRMS to consider reclamation blasting to be unnecessary for portions of the pits to be backfilied, then
the language in AM-09 allowing essentially total flexibility in the implementation of pit backfilling must be
rescinded, and reclamation cost estimates to allow bonding for backfilling, at the point in the mine plan when those
costs would be maximized, must be provided.
c:\acs files\My Documents 4-19-06 thru\cresson am9 mine slope review 2.doc
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Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines