2017-08-01_REVISION - M1977534 (4)

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Date: July 25, 2017 To: Michael A. Cunningham, Environmental Protection Specialist REVENF-9 Colorado Division of Reclamation Mining and Safety Department of Natural Resources 1313 Sherman Street, Room 215 Denver, CO 80203 DIVISION OF RECLAMATION MINING AND SAFETY Re: City of Golden, Empire Pit No. M-1977-534-SL02 Reclamation Permit Release Request Consideration Dear Mr. Cunningham: I The purpose of this letter is to object to releasing the reclamation permit and to ask for help in completing the reclamation of the Guanella g vra el area used by City of Golden. The reclamation process of the soil and of the vegetation of the Site have not been successful or completed. The seed sown germinated and plants have only grown into a sparse vegetation cover with many weeds present. Clear Creek County also has noted the invasive weed species. Most areas have little grass and there are many areas that are barren with asphalt and salt on the surface and other areas with just weeds. The vegetation condition has worsened since the last inspection. We are concerned that this is evidence that all the debris and foreign material that was buried by the contractor has not been removed. The imported material that was used to mix with the soil amendment was contaminated with weed seeds, rocks and other debris. Larger rocks have recently been added to areas attempting to control erosion rather than concave sloping. And areas on the south side have not been blended into the hill sides nor reseeded. The removed south fence still has not been reinstalled to complete the enclosure. No sandy clay silt was added to the gravel areas to protect the surface soils or amendments from being migrated away by wind or water. The surface remains a gravelly cobbled coarse surface rather than topsoil consisting of friable soil of natural loam with humus that can sustain plant life. It also contains foreign materials, stones greater than one inch, asphalt, salt, weeds and noxious materials. The top soiling material that was spread as a thin layer on the gravel rather than subsoil has disappeared. We hired Samuel Bamberg, PhD, Environmental Consultant with Environmental Services and he gave us his opinion along the lines of the above stated problems. We also sent soil samples to Colorado State University for testing. The results indicated high pH, high salts, and low organic matter. Sincerely, 1R O Glenda Guanella Sally Guanella Buckland