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© MONH <br />MONTGOMERYWATSON HARZA <br />March 26, 2003 <br />Mr. Jim R. Burnell <br />Colorado Division of Minerals & Geology <br />1313 Sherman Street -Room 215 <br />Denver, Colorado 80203 <br />(303) 866-3567 <br />RECEIVED <br />MAR 2 S 2003 <br />Division of Minerals and Geology <br />Re: Oxbow Mining, LLC (Permit C-81-022), Minor Revision (MR-67) for Revision of Soil <br />Material Volumetrics <br />Dear Mr. Burnell: <br />In response to your recent inquiries regarding a final survey for the North Elk Creek Soil <br />Stockpile, Oxbow Mining, LLC (OMLLC) has obtained survey data from the earthwork contractor <br />and completed updared volumetric calculations for the soil stockpile. OMLLC has updated and <br />enclosed three copies of the following soils volumetric information from the permit document to <br />reflect this new information, and is requesting CDMG approval of a Minor Revision (MR-67) to <br />incorporate the updated soils volumetric information in the permit. <br />Page 2.05-24 (Mine Facilities discussion under Operations Plan -Permit Area) <br />Exhibit 2.05-E5, Reclamation Details, Soil Recovery and Replacement Plan <br />As noted in the exhibit discussions, the North Elk Creek Soil Stockpile contains all soil from the <br />previous East Yard and Elk Creek soil stockpiles, as well as all soil recovered from the West Valley <br />Fill, West Valley Haul Road, Pond C, Pond CLight-Use Road, and Elk Creek Mine Surface <br />Facilities (includes the recent rock dust tank disturbance). With the recent updates, Table 2.05-ES- <br />Tl, Soil Recovery and Replacement Summary, identifies final soil salvage volumes and the amount <br />of soil available for future reclamation, consistent with the requirements of Stipulation No. 25. It <br />should be noted that, because of practical operational considerations (operational load counts are <br />not typically very accurate due to varying fill Eactors, etc.), soil salvage volumes were determined <br />based on soil stockpIle surveys. Given this considexadon, information on soil salvage volumes is <br />available on a "project" basis (i.e., West Valley Fill and Haul Road) but not on an individual area <br />basis (i.e.,: West Valley Fill, West Valley Haul Road, Pond C, Pond CLight-Use Road). Ic is our <br />understanding that the information provided by this Minor Revision application should effett <br />compliance with Stipulation No. 25, allowing elimination of the outstanding stipulation. <br />In the course of reviewing and editing potentiall}~ applicable permit sections, we noted a <br />discrepancy in the Soil Recovery and Replacement Plan relative to soil replacement practices for <br />the West Valley Fill. During the West Valley Fill and Haul Road construction project, <br />approximately 10,400 cubic yards of soil material were recovered and placed in the Elk Creek Soil <br />Stockpile. This material came primarily from the Pond C area and the portion of the West Valley <br />Haul Road within the Elk Creek drainage. Given the source of these materials and timing <br />considerations relative to progressive construction of the West Valley Fill, OMLLC did not intend <br />to replace these soil materials on the completed West Valley Fill, as indicated by text references in <br />the approved Soil Recovery and Replacement Plan. <br />P.O. Box 774018 Tel: 970 879 62fi0 Delivering Innovative Projects and Solutions Worldwide <br />1475 Pine Grove Road, Suite 109 Fax: 970 879 9048 <br />Steamboat Springs, Colorado <br />80477 <br />