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OBSERVATIONS <br />PERMIT #: M- 1977 -284 <br />INSPECTOR'S INITIALS: GRM <br />INSPECTION DATE: September 20, 2011 <br />This inspection is part of the normal inspection schedule for Designated Mining Operations by the Colorado Division of <br />Reclamation, Mining, and Safety (Division). The Mineral Joe is a 110d permit, located on the south rim of Paradox Valley <br />in Western Montrose County. Glen Williams, Cotter's representative, accompanied the inspector on site. <br />The Mineral Joe Mine is a partial reclaimed mine site at split into three areas. On the upper bench: the main mine area, <br />support facilities, and waste piles have been reclaimed with the exception of the Mineral Joe #12 shaft. The shaft had <br />been planned to be utilized as part of the JD -6 Mine operations. However, further investigation discovered the shaft <br />was caved in and not usable. A small portal is located on the west side of the County Road DD -19 which is used as an <br />emergency escape -way for the JD -6 operations. The Duggan Adit is utilized as the main access to the JD -6 DOE lease <br />tract and is located on a lower bench. This area will be addressed within the inspection for the JD -6. <br />The mine identification sign and affected area boundary markers are not considered an issue as the main disturbance is <br />part of the JD -6 which is marked. <br />The waste piles edges of the upper bench are sloped at 2:1 or better. The slopes are noted as being very stable with no <br />erosion or sedimentation issues observed. The piles, support, and office area are fully re- vegetated and are equal to or <br />better than the surrounding area. Density and diversity of vegetation is very good. Four winged and rabbit brushes are <br />predominant with native grasses and minor shrubs filling in. Some pinyons were noted as coming in as well. With the <br />exception final reclamation of the shaft this area is fully reclaimed. <br />The emergency escape -way portal is currently in disrepair. The small historic waste pile has marginal vegetation and <br />would not be releasable at this time. Grading and sloping are better than 2:1. It is recommended that the operator top <br />seed this area this fall or next spring. <br />Overall the site is partially releasable. The Division is recommending to Cotter that it seek partial release of the permit <br />and combining the remainder with the JD -6 Mine permit based on several factors. First the main upper site meets the <br />reclamation standards presently in place for the permit with the exception of the shaft. Other areas could be <br />consolidated into the 1D -6 permit with the pending Environmental Protect Plans (EPP). While it may push the JD -6 to a <br />112d, it would consolidate all the compliance, costs, and reporting requirements into one permit. Additionally there has <br />always been some confusion on paper over the relationship of the JD -6 and Mineral Joe which would be cleared up if it <br />was covered under one permit. The Mineral Joe might create unnecessary additional permitting requirements for the <br />operator and confusion in the EPP process. Secondly, the permit is out of date and would require an entire permit <br />update not just an EPP. A new permit later, if reopening was feasible, would be up to date and meet current standards. <br />The process is the same for an amendment or a new permit and nothing is gained by keeping the old permit. Finally, the <br />Division is reviewing the intermittent status issue for all mining permits. It is probable that a shift in the status of this <br />permit could create conditions where Cotter will have to either reactivate the mine or seek release anyway. <br />Responses to this inspection report should be directed to Russ Means at the Division of Reclamation, Mining, and Safety, <br />Grand Junction Field Office, 101 South 3rd Street, Room 301, Grand Junction, Colorado 81501, phone no. 970 - 241 -1117. <br />Inspection Contact Address <br />Glen Williams <br />Cotter Corporation <br />P.O. Box 700 <br />Nucla, CO 81424 <br />Page 2 of 2 <br />