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DESERADO <br />BLUE MOUNTAIN <br />3607 County Rd. 65 <br />Rangely, CO 81648 <br />(970)675-4300 <br />fax (970)675-4399 <br />May 23, 2011 <br />RECEIVED <br />Mr. Jim Stark MAY 2 5 2011 <br />Division of Reclamation, Mining and Safety Divi-.)-, .,, -:ecJamatiart, <br />1313 Sherman Street, Room 215 Mining and Safety <br />Denver, CO 80203 <br />RE: Technical Revision #68 - B-Seam Dewatering System <br />Deserado Mine - Permit No. C-1981-018 <br />Response to Adequacy Review <br />Dear Jim: <br />The following is our response to the Preliminary Adequacy Review addressing Technical Revision <br />68 dated April 19, 2011. Itemized responses corresponds to the itemized questions and comments <br />found within the review. <br />1. No response necessary. Comment noted <br />2. While we don't see the confusion mentioned given the complete integration of SH-3 to the <br />dewatering system Table V-3, page V-25 has been amended as suggested. <br />3. SDH-4 is discussed on page IV-38 of the original submittal. As stated in this discussion, <br />the originally proposed ponds and facilities were never constructed. These ponds and facilities <br />are the focus of Maps 141, 144, and 145. Without these facilities SDH-4 becomes nothing more <br />than a plugged and reclaimed drill hole. Retention of these maps only confuses the reader and <br />they need to be removed. They serve no useful purpose within the context of the mining permit. <br />This comment is a prime example of the confusion that these `historic' maps can create when they <br />are not removed from a permit. <br />Please revise the bond accordingly to reduce the liability for these facilities which were never <br />constructed and never will be. <br />4. The reclamation estimate includes a perennial problem the Division has with estimating <br />seed costs. We have attached a table comparing DRMS estimates verse published prices from <br />Pawnee Butte Seed and BME's actual price received from Granite Seed late last fall. Pricing that <br />the Division or contractor would receive should be comparable to these prices or less given the <br />quantities involved with a project as large as the final closure. Specifically, the Division estimates <br />a cost per acre of seed of $236.30 while the current advertised prices from Pawnee Butte for this <br />seed mix is $124.75 and a similar mix purchased from Granite Seed by BME last fall was $120.75 <br />per acre. <br />INANE <br />ENERGY <br />