2008-12-12_INSPECTION - M1980244

• Permit No: M1980244
• IBM Index Class Name: INSPECTION
• Doc Date: 12/12/2008
• Doc Name: Meeting and Inspection
• From: DRMS-acs
• To: DRMS-bmk
• Inspection Date: 11/20/2008
• 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 C O L O R A D O

Phone: [phone] D IV IS I ON OF
RECLAMATION
FAX: [phone] MINING

SAFETY
Bill Ritter, Jr.
DATE: December 12, 2008 Governor
Harris D. Sherman
TO: Berhan Keffelew Executive Director

FROM: Allen Sorenson Ronald W. Cattany
Division Director
Natural Resource Trustee
RE: Meeting and Inspection at Cresson Project, Cripple Creek and
-
Victor Gold Mining Company, Permit No. M-1980-244 1i
On November 20, 2008, while you and Jeff Fugate of the Attorney General's Office (AGO) were inspecting the
Carlton Tunnel Portal, I and Peter Hack of the AGO met with Cripple Creek and Victor (CC&V) personnel Alec
Keith, Gary Goodrich, and Tim Comer to discuss open pit mining at the Cresson Project as it relates to reclamation
bonding requirements. Following the meeting the open pits were inspected. This memo provides a summary of
meeting discussions and agreements with reference to the terms of the permit, and a description of the inspection
observations.
It is stated in appendix 5 to volume IV of the AM-09 application that "Construction of the mine walls to the design
slopes presented in Table 1 requires the following excavation techniques" (emphasis added). The excavation
techniques referenced in this statement are:
1. Light trim or pre-split blasting against the final wall with close spaced holes (maximum five feet).
2. Two foot sub-drilling at the toe of the slope to prevent the formation of a hard toe, which results in a wedge
at the base of the toe that can result in any falling rock being propelled laterally out onto the working level
3. Avoidance of disturbing the next bench crest by:
a. Aligning blast hole lines so that the next crest falls equidistant from two blast hole lines.
b. Not sub-drilling blast holes on the two lines that straddle the future crest location
4. Loading the holes in the vicinity of the final wall and bench as lightly as is consistent with required
breakage.
5. Scaling to remove loose and hanging material from the slope.
Therefore, absent backfilling, execution of these five excavation techniques is necessary for all final open pit walls,
both because it is requirement of the permit, and to meet the performance standard of rule 3.1.5(3), which states
"(i)f not eliminated, all highwalls shall be stabilized."
The issue of concern, as it relates to the foregoing reclamation requirements is that:
1. There is no money dedicated to pit wall stabilization in the reclamation cost estimate that is the basis for the
amount of financial warranty required under the approved permit amendment AM-09.
2. There are no enforceable limitations contained in the reclamation permit on the amounts or configurations
of un-reclaimed pit walls that can be extant in the open pits during at any point(s) in the life of the mine.
As a result, even if the approved mine plan is followed meticulously, with the properly and appropriately allowed
flexibilities contained therein, there may be substantial amounts of pit wall reclamation work required under a bond
forfeiture situation that are not addressed in either the current bond, nor in the bond required going forward from
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines