2012-10-25_REVISION - C1991078

• Permit No: C1991078
• IBM Index Class Name: Revision
• Doc Date: 10/25/2012
• Doc Name: Adequacy Reviiew No. 2
• From: DRMS
• To: Mr. Jim Stover J.E. Stover and Associates, Inc
• Type & Sequence: SL3
• Email Name: JLE
• Email Name: SB1
• Media Type: D
• Archive: No

STATE OF COLORADO
DIVISION OF RECLAMATION, MINING AND SAFETY
Department of Natural Resources
1313 Sherman St., Room 215
CO L D RA D O
D I V I S I O N o f
Denver, Colorado 80203
N
Phone: [phone]
M I N I NTG
FAX: [phone]
—&—
SAFETY
October 25, 2012
John W. Hickenlooper
Governor
Mr. Jim Stover
J.E. Stover and Associates, Inc.
Mike King
2352 North 7th Street, Unit B.
Executive Director
Grand Junction, Colorado 81501
Loretta Pineda
Director
RE: Hamilton Mine; C- 1991 -078
Phase III Bond Release (SL3), Adequacy Review No. 2
Dear Mr. Stover,
The Division as identified a discrepancy in the bond release application while conducting a review of your
response letter dated October 1, 2012. The SL3 bond release application indicates 90.2 acres has been approved
for Phase II bond release. However, based on the application submitted for SL2, only 86.8 acres of the disturbed
land was requested and subsequently approved for phase II bond release. There is a discrepancy in 3.4 acres that
have not been approved for Phase II release. Please address the items below:
Total Disturbed Area
1.) Annual reports and the SL3 application indicate only 111.2 acres had been disturbed at the Hamilton
Mine. Of those 90.2 acres were revegetated in 1993, 1995 and 1998. Based on the Division's review,
these 90.2 acres is comprised of Mining Area 1 (73.1 acres), Mine Area 3 (9.9 acres), Topsoil
Stockpile 1 area (3.4 acres, pile and accompanying disturbance), Topsoil Stockpile 2 (1.3 acres) and
Topsoil Stockpile 3 area (2.5 acres). The 90.2 acres does not include the 1.6 acres attributed to the
Pond A reclamation based on the acreages calculated and identified for the features previously listed.
The SL3 application indicates 21 acres are "permanent facilities ". The 90.2 acres of revegetated land,
plus the 1.6 acres for Pond A, plus the 21 acres for permanent facilities equals 112.8 acres of total
disturbance. This does not appear to be correct given only 111.2 acres has only ever been reported as
being disturbed. Given this, there is a discrepancy in 1.6 acres of total disturbed area.
Up until 2010 for the Annual Reclamation Reports submitted to the Division, the Operator has
reported 21 acres attributed to "acreage in long -term mining or reclamation facilities ". In 2010, Pond
A was reclaimed, so according to the report this acreage was reduced to 19.4 acres. This is a
reduction of 1.6 acres. The Division assumes this 1.6 acres was counted in the "permanent facilities"
acreage reported in SL3. Please affirm, is the Division's analysis correct? If not, please explain this
discrepancy.
Phase II Bond Release Area
2.) As indicated above, 3.4 acres of land associated with what appears to be the Topsoil Stockpile 1 area
has not been approved for Phase II bond release. In order for this parcel to qualify for total Phase III
bond release, it must also meet the Phase II criteria. Data has already been submitted that the
Division can use to determine if this area meets both the Phase II and Phase III bind release
requirements such as vegetation monitoring data submitted with SL3 and section 2.05.3(4) of the
permit for the Total Suspended Solids demonstration. However there are a few additional pieces of
information the Division needs to address this issue. For this 3.4 acre parcel, please submit the
following:
Office of Office of
Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines