2016-10-12_REVISION - M1977559

• Permit No: M1977559
• IBM Index Class Name: Revision
• Doc Date: 10/12/2016
• Doc Name: Adequacy Review Response
• From: Valco, Inc.
• To: DRMS
• Type & Sequence: TR4
• Email Name: TC1
• Media Type: D
• Archive: No

v VALCO, INC.
9296 Windhaven Drive
Parker, CO 80134
RECEIVE® [phone]
�
v OCT 122016
O RECUWATO
October 5, 2016 WMJ'DSAFE'TY
Mr. Timothy Cazier
Colorado Division of Reclamation, Mining and Safety
Department of National Resources
1313 Sherman Street, Room 215
Denver, Colorado 9020(3
Re: Project, Permit No. M-1977-559
Technical Revisions (TR-04) Preliminary Adequacy Review
cv
Dear Mr. Cazier:
On September 2, 2016, Valco, Inc. (Valco) received the Colorado Division of Reclamation,
Mining and 'Safety's (Division's) response to Valco's Request for Technical Revision for the
Canon City East Pit (aka Mackenzie Pit), M-1977-559, (the Site), which was submitted to the
Division on August 19, 2016. In the Division's response, you indicated that the application was
complete for the purpose of filing on August 23, 2016, but identified several outstanding issues to
be addressed prior to the end of the review period on September 22.2016,or any extension thereof.
Valco has requested and understands that the Division has approved an extension of the review
period to October 21, 2016.
Responses to the Division's comments follow:
1. Fremont County zoning regulations. The Division requested demonstration that the
intent to leave aggregate storage bunkers is not in violation of county zoning regulations.
It is not clear at this time whether or not Fremont County will require an additional permit
for those structures to remain in use under the County's zoning ordinance. Thus, Valco
requests that DRMS condition approval to leave aggregate storage bunkers.on obtaining
any required permit from Fremont County. If a permit is required, but not granted, by
Fremont County, the structures will be demolished. Demolition of structures is
contemplated by the existing reclamation plan,and,therefore, should not affect the existing
financial warranty for the Site.
2. Structures previously used for fuel and storage. The Division requested demonstration
that concrete to be used in,the water for stabilization-and/or fish habitat would not be
exposed to petroleum product spills. The concrete intended for this use indicates only a
small amount of staining associated with petroleum products. The Phase I Environmental
Site Assessment completed this summer indicates that the observed staining was limited to
an area around a 5-gallon bucket and would likely be considered a de minimis condition.
The following is the ASTM definition of a de minimis condition: