2008-10-10_REVISION - M1980244

• Permit No: M1980244
• IBM Index Class Name: REVISION
• Doc Date: 10/10/2008
• Doc Name: Third Review of Surface Mine Slope Design
• From: DRMS-acs
• To: DRMS-bmk
• Type & Sequence: AM9
• Email Name: BMK
• 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]
COLORADO
D I V1 S I ON OF
RECLAMATION
MINING
SAFETY
Bill Ritter, Jr.
Governor
DATE: October 10, 2008 Harris D. Sherman
Executive Director
TO: Berhan Keffelew Ronald W. Cattany
Division Director

FROM:
Allen Sorenson Natural Resource Trustee
RE: Third Review of Surface Mine Slope Design, Cripple 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 section of Cripple
Creek and Victor Gold Mining Company's (CC&V) response to adequacy review dated October 3, 2008 pertaining
to mine slopes. Therein CC&V states that at no time during the period of mining will production faces in the pits
be located anywhere other than the floor of a pit, and that the production faces will be no higher than 35 feet in
height. This means that CC&V will always complete each 35 foot production lift to its full extent and stabilize the
final walls of that lift by special blasting and scaling prior to initiating blasting and excavation of the next
production lift below. If this is the basis that CC&V wants the DRMS to use in considering the need for bond to
conduct necessary special blasting and scaling of production faces that may be present at the time of a bond
forfeiture, then CC&V must provide an enforceable permit commitment that so states and must recognize that if
through inspection or otherwise the DRMS determines that more than one production lift is being excavated at any
time in any of the pits, such a circumstance would be a violation of the permit.
CC&V further states that production faces in each individual lift are stable as mined and only rock scaling would
be required to stabilize these faces in a bond forfeiture situation. This statement implies that special blasting of
production faces as prescribed in section 4.1 of appendix 5 to volume IV of the AM-09 application is only for the
purposes of preventing the formation of a hard toe and avoidance of disturbance to the next bench crest. The
DRMS rejects the position that only scaling and not special blasting is necessary for reclamation of production
faces. The special blasting not only facilitates the hard toe prevention and next bench creation, but also better
preserves existing intact rock bridges across rock joints, and is thus necessary to creation of all rock faces for
reclamation.
CC&V states that any money that may be needed for reclamation of production faces that may be present at the
time of a bond forfeiture would be available from funds in the bond dedicated, through the line item cost estimating
that forms the basis of the bond amount, to other reclamation tasks that presumably would not be necessary at the
time of such a bond forfeiture. The DRMS can accept such a premise only with the presentation by CC&V of a
specific demonstration at critical points in the life of the mine where specific areas of mine wall would require
reclamation blasting and scaling and detailing at that same critical point in the life of the mine which bond monies
dedicated to other reclamation tasks would be available to complete this work by specific detailed demonstration
that the other bonded reclamation work would not need to be done because the disturbances requiring that
reclamation had not yet occurred.
As an example, exhibit C-5 to the AM-09 application shows that during mine plan year 2015 there may be as much
as 21,700 linear feet of production face developed in the South Cresson, Wildhorse Extension, Globe Hill, and
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Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines