2011-10-04_INSPECTION - M1977284

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