REP01466

• Permit No: M1977424
• IBM Index Class Name: Report
• Doc Date: 7/18/2005
• Doc Name: response to request
• From: dmg
• To: western water and land inc
• Media Type: D
• Archive: No

STATE OF
fff'
COLORADO
DIVISION OF MINERALS AND GEOLOGY v'
Department of Natural Resources
1313 Sherman St., Room 215 C O L O~ D ~
Denver, Colorado 80203 o I v 15 1 0 1N O F
Phone: [phone] M 111 ERA L $
FAX: [phone] R~
C G E O L O G Y
F~V~lr~ 0.E SRFETY'OUENfCENG
~~C 8 BillOwens
~th.4j 8 ~oOM Governor
July 12, 2005 ~~rMrgeia/d aq Russell George
d Gl'4rJt/Y Executive Director
Mr. BI'l1Ce D Smlth ~ Ronald W. Cattany
> / Division Direcor
Wastern Water and Land, InC. Natural Resource Trustee
743 Horizon Court, Suite 330
Grand Junction, Colorado 81506 /
RE Logan Wash P it No. M-1977-424, Response to Request for DMG Opinion on Soil Borrow Areas v
Deaz Mr. Smith:
Division of Minerals and Geology (DMG) received your June 15, 2005 request for an opinion on permitting
requirements for each of four potential topsoil borrow areas. The topsoil from these areas is to be used to satisfy
requirements of the reclamation plan for the Logan Wash mine.
To render an accurate response, some clarification is necessary. This response will be based on the scenario whereby
Occidental Oil Shale, Ina {OOSI) takes the appropriate measures to allow their sister company, Occidental Gas
Company, to use the majority of the lower bench for gas drilling pads. This will require submittal of documentation
that reasonably guarantees the designated areas will be utilized for the gas drilling, and submittal of a technical revision
that details the specific areas to be set aside for these operations. OOSI may wish to consider removal of these areas
from the permit upon approval of the revision, based on the reclamation responsibility being shifted to the sister
company who is liable to another state agency (Colorado Oil and Gas Commission) for reclamation of that portion of
the site. Documentation of BLM approval will be required for any proposed gas operations and any proposed
permanent retention ofmine features within the Logan'Wash permit area, including the access road, that lie on surface
property controlled by them. Depending on the extent of the proposed gas drilling activities, a change ofpost-mining
land use for these areas may be required.
Please advise DMG of how OOSI would like to proceed with the pending release request (SL-01) that requests release
from reclamation responsibility for most of the areas described in this soil scavenging proposal.
Area No. 1: Based on information supplied in SL-01 and the permit, it appears that approximatelytwo acres, designated
to be affected by mining operations, were not ever disturbed in this quarter-quarter section. Therefore, a technical
revision with details regarding topsoil scavenging operations would be appropriate for up to two acres of additional
disturbed area in the NE/4 NE/4 Section 25, T7S, R97 W. An amendment to the permit, or a new 110c permit would be
required to extend disturbance into the SE/4 SE/4 of Section 24, T7S, R97W.
Area No. 2: Any mining related disturbance in Section 18, T7S, R96W would require an amendment to the Logan
Wash permit or submittal of a new 110c permit application The current permit document does not identify Section ] 8
as a location for any mining related disturbance and does not include any acreage from Section 18 in the specified
overall disturbance figure of 134.7 acres. If, in fact, the specified disturbance in Section 18 was due to jurisdictional
Logan Wash mine activity, it may have been constructed in violation of the Mined Land Reclamation Act and the Hazd
Office of ~ Of(ice of Colorado