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PIKES PEAK 11/~ING COMPANY Operations Office P. O. Box 191 2755 State Highway 67 Victor, Colorado 80860 (7191 689-2977 Fax (7191 689-3254 October 28, 1997 Mr. Michael B. Long, Director Division of Minerals and Geology Colorado Department of Natural Resources 1313 Sherman Street, Room 215 Denver, Colorado 80203 ~ G~A, Re: Overburden Handling Cresson Protect\_J, Dear Mike n u Englewood Office sss 5251 DTC Parkway Suite 700 Englewood, Colorado 80111 (3031 889-0700 • Fax (3031 889-0707 "r~Fl1,~b-p OCT 2 g 1997 ,,, ,., ,..~,~m..w a ueciony As a follow up to our recent discussion concerning the commentary in Amendment No. 6 (i.e. the Cresson Project) regarding possible lime additions to certain overburden storage areas, I have prepared this letter. T}re brief response to this issue is that the language dealing with lime additions is not applicable to [he current cpcntion. The approach which described possible lime use was replaced with the current approved practice of assaying and separately handling lower and higher sulfur containing overburden material. 1 will set forth a brief history below. The initial proposal by CC&V was to do a visible pyrite sulfur assessment of the overburden material and then, if necessary, selectively handle the overburden and add lime to certain locations within the overburden storage aeeas containine higher concentrations of pyrite based upon the visual assessment. This process was spelled out in a letter from John Hardaway to Berhan Keffelew, dated April 9, 1994, in Attachment ~ at pages 47 - 48. As you may know, afrer extensive negotiations and discussions with DMG this proposed CC&V approach was rejected by DMG. Our proposed approach •was replaced with the current practice employed at the operation as approved by Div1G. This practice requires CC&V to assay all of its overburden material and determine the total sulfur concentration thereof. CC&V then places material [hat contains more than 0.8% sulfur in one storage area (i.e., Ironclad - Globehill pits) mul material of lesser concentrations in other storage areas. This latter practice was reflected in a report submitted by CC&V to DMG dated September, 1994 and is located in Volume 7C of Amendment No. 6. The confusion that has apparently arisen results from a simple fact. In dte course of reviewing and approving the practice wluch is currently employed by CC&V and embodied iu Amendment No. 6, CC&V and DMG failed to expressly delete the language which was superseded by the latter approach. This superseded language is contained in documents which constituted a portion of the original permit application which were not intended to be part of the f nal permit.