2009-11-30_REVISION - M1997064 (3)

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November 20, 2009 Division of Reclamation, Mining and Safety 1313 Sherman Street, Room 215 Denver, Colorado 80203 RE: GCC /Salt Canyon M- 1997 -064 112 Conversion Application Adequacy Response Dear Mr. Keffelew, NOVA Cb�/ Please accept the following as response to the Divisions adequacy concerns dated November 16, 2009. I. Exhibit A Legal Description 6.4.1 a. The legal description provided by the State of Colorado states the leased land is 592.42 acres. Upon performing a land survey, 559.22 acres were determined to exist inside the State's legal description. It is surmised that the difference is within the CDOT right -of -way. Only those acres outside the CDOT right -of -way are proposed to be in the permit boundary. II. Exhibit D Mining Plan 6.4.4 a. Rather than stockpiling growth medium during initial site development, salvaged growth medium will be placed on the Western Nutrients disturbance, followed by a temporary seed mix to perform temporary reclamation of the disturbance. The proposed mine plan does not include growth medium stockpiling as the material will be placed on mined out areas as mining proceeds through the gypsum deposit. b. The preferred mining technique is pushing material to the mine floor with a dozer and maintaining a 3:1 slope. In the event the gypsum crumbles under the weight of the dozer, temporary 50 foot wide benches will be constructed for every ten feet of vertical height with an average gypsum thickness of 30 feet. Due to requirements by the Mine Safety and Health Administrations regarding miner safety and mine design, the operator would prefer the option to construct benches immediately upon determining the need. Bench construction would produce slope reconstruction with a slope less than 3:1 over the existing bench. Enq \V1 ronrgenLcca //,�IlLC (2-2rnaLcL ii\Vre c, 1107 Main Street, Canon City, CO 81212 www.envalternatives.com • e -mail: eai @bresnan.net Phone: 719 - 275 -8951 • Fax: 719 - 275 -1715 F -' //II