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. , <br />III IIIIIIIIIIIII III <br />999 <br />~~ <br />August 2, 2001 AUG ®6 2001 <br />ENERGY, INC. DiCv7ision Junction Field Office <br />~s~e:ld~ef of Minerals $ Geolo <br />n..~Mc~,,.,•eo•s Mr. Dan Mathews ev <br />r..kmv,e• coearm+~ Division of Mineral and Geology <br />101 South 3'd, Suite 301 <br />Grand Junction, CO 81501 <br />RE: Technical Revision #54 -East Portal Reclamation/Sediment Control <br />Deserado Mine - Permit No. C-1981-018 <br />Dear Dan: <br />Per our meeting of July 20, the attached Map 89 and supporting SedCAD models of the <br />referenced structures were performed to our understanding of DMG's desired configuration for <br />the East Portal reclamation. <br />In your June 22, 2001 comment letter issue was taken in reference to sediment control measures <br />for the access road. It was stated that "...the Scullion Gulch channel is immediately adjacent to <br />the toe of the reclamation." This is the case in only one short segment of the road. Sufficient <br />vegetation exists along the toe of the majority of the access road to adequately control <br />sedimentation from runoff provided other control practices are used as proposed. DMG implies <br />that silt fences or berms to silt fence outlets would be required by DMG along the entire length <br />of the reclaimed road. While BME agrees that such structures may be appropriate on an isolated <br />basis they are not necessary along the entire road to meet the objectives of 4.03.2(4)(b). <br />Installation of these structwes also would require eventual removal and re-disturbance or <br />permanent retention. The BLM has previously voices their opposition to such practices. <br />Furthermore, maintenance of silt fence along the toe of the road would require appropriate <br />access. Once reclaimed to the proposed grade no general access with equipment would be <br />reasonably possible without constructing another road. The access road originally followed pre- <br />law access to the Staley-Gordon Mine. While it is neither the desire nor the intent of BME to <br />retain access to this mine, rigorous sediment control requirements would necessitate retention of <br />this access as part of the post-mine topography for periodic maintenance. <br />BME's proposed erosion control measures for the access road include the following to be field <br />fit as conditions warrant: <br />^ Grass filters. <br />• Surface roughening <br />• Revegetation <br />^ Mulching <br />• Rock channels <br />• Straw bale checks <br />3607 Cowry RD p65 <br />Rengely, CO 81648 <br />970-6734700 <br />Fex 970fi734799 <br />