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14T00 ly United States Department of the Interior <br />BUREAU OF RECLAMATION <br />:. }44 . <br />Western Colorado Area Office <br />"Ag <br />gRCH <br />Durango Field Division <br />3.�a <br />185 Suttle Street, Suite 2 <br />Durango, Colorado 81303 -7911 <br />W REPLF REFER TO <br />WCD- TArtichoker <br />LND -8.00 <br />APR 16 2014 <br />VIA FEDERAL EXPRESS <br />Ms. Kate Pickford <br />Environmental Protection Specialist <br />Colorado Division of Reclamation, <br />Mining and Safety <br />1313 Sherman Street, Room 215 <br />Denver, CO 80203 <br />Subject: Agency Comments for Technical Revision to Oldcastle SW Group, Inc. dba Four <br />Corners Materials (FCM), Animas Glacier Gravel (AGG), Colorado Division of <br />Reclamation, Mining and Safety (CDRMS), Permit No. M- 20.1.1 -028-, Animas -La Plata <br />Project, Colorado and New Mexico <br />Dear Ms. Pickford: <br />This letter is in response to your notice dated April 1, 2014 and recent communications in the <br />subject matter, both for the original permitting action, Bureau of Reclamation's original <br />comments to the original permitting action, the technical revision and Reclamation's comments <br />regarding the technical revision. While we are grateful for the continued efforts to find a viable <br />solution that is not grossly cumbersome upon the applicant, we still have concerns with the <br />revision and original permit application in regards to serious risk to the waters and delivery <br />infrastructure downstream of the AGG site. <br />The most recent round of documents received by Reclamation improves upon the exchange of <br />information, but lacks sufficient detail to answer some concerns and initiates additional <br />questions. One example stems from the Drainage Report — Amendment 1 from Russell <br />Engineering dated March 28, 2014. It mentions that only the 4.8 AF retention pond is lined and <br />thus no infiltration, but that the other 215.2 AF maximum capacity storage is capable to infiltrate <br />0.60 inches per hour. Given the stated 80 AF maximum winter month storage and a 24 -hour <br />Probable Maximum Precipitation (PMP) event of 42 AF, it is possible to see a situation where <br />122 AF are impounded by the berm, with the retention stated to be at least one month before <br />used, evaporated and/or infiltrated. At what point does the berm cease to become a berm and <br />become an earthen dam? Where does the infiltration water flow and discharge? Is the berm <br />sufficiently rated to withstand this impoundment? <br />Furthermore, detailed comments submitted by Reclamation dated February 20, 2014 have not <br />been fully addressed. The State's original requirement that construction activities other than the <br />access road, were not to commence prior to full satisfaction of permitting requirements. FCM <br />