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DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866 -3567 <br />FAX: (303) 832 -8106 <br />DATE: 29 August 2011 <br />TO: Russ Means <br />FROM: David Bird dh <br />TECHNICAL MEMORANDUM <br />STATE OF COLORADO <br />RE: Review of Environmental Protection Plan for Cotter Corporation JD -8 Mine <br />M -1984 -014 <br />The following adequacy comments are provided in response to the Applicant's Environmental <br />Protection Plan that was filed with the Division on 8 June 2011. <br />Mined Land Reclamation <br />COLORADO <br />D I V I S I O N O F <br />RECLAMATION <br />MINING <br />- &- <br />SAFETY <br />John W. Hickenlooper <br />Governor <br />Mike King <br />Executive Director <br />Loretta E. Pi Leda <br />Director <br />1) Exhibit C, pg. C -1: The Applicant states: "There are no creeks or oil and gas wells located <br />either on or within 200 feet of the current or proposed affected areas." This statement may <br />mislead the reader into believing that the requirements of Rule 6.4.21(8)(a) have not been <br />addressed when in fact they have been addressed in the appropriate section of Exhibit U. <br />Conflicting passages such as this should be avoided. <br />2) Exhibit D and Exhibit U: The Applicant states that mine waste material will be gobbed in the <br />mined out stopes and in lifts on ground surface. The Applicant is advised that any mine <br />development waste rock that will be disposed of in the underground workings must be subjected <br />to the same geochemical characterization as waste rock proposed for disposal above ground. <br />Future geochemical characterization programs must be developed in consultation with the <br />Division. Failure to do so may result in the testing parameters not meeting Division <br />requirements and the possibility of having to repeat portions of the tests. <br />3) Exhibit E, pg. E -1: "The material immediately below the proposed ore storage pad will be <br />removed and dumped in the shaft prior to plugging the shaft." The applicant should describe in <br />detail the physical and geologic nature of this material. <br />4) Section 4, pg 7. Facilities Evaluation. Diesel is not a designated chemical and unless other <br />chemicals are planned for storage in that facility, its storage area does not need to be an <br />Environmental Protection Facility. <br />Office of Office of <br />Denver • Grand Junction • Durango Active and Inactive Mines <br />