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Summit Brick and Tile Company Fox No 1 Clay Pit <br /> M-1977-219 -Adequacy Response#1 November 13, 2017 <br /> clay seams remaining at 3H:IV. Within the Mining Plan narrative, the Applicant states <br /> that it makes little economic sense to reclaim the slopes since vertical faces of solid <br /> sandstone are stable. In accordance with Rule 6.5(2), the Applicant shall provide <br /> engineering stability analyses for the proposed mining and final reclaimed slopes which <br /> demonstrates that structures and off-site areas will be protected. Please note, the <br /> Division's acceptable minimum factor of safety for static conditions is 1.3 and seismic is <br /> 1.1. <br /> We don' t look at it as downgrading the slopes as we still plan to <br /> reclaim the slopes above and below the sandstone that are <br /> susceptible to erosion as 3h to 1V slopes like currently <br /> approved. The change is to the very hard sandstone material that <br /> is found on the site between the surface layer and the clay. <br /> Much of the sidewalls in each canyon area has this exposed <br /> sandstone that has stood up to weathering for many eons and is <br /> stable . When the original Reclamation Plans were written the <br /> operators had a need to dispose of large quantities of waste rock <br /> so they committed to using it to built 3h to 1v slopes . Summit <br /> Brick has developed a market for this material and pays the <br /> lessees a royalty for it' s removal . This means that it is no <br /> longer wasted rebuilding unneeded slopes . We are working on the <br /> Stability Analysis and will submit it as soon as available . In <br /> the mean time Summit Brick and Tile Company will commit to not <br /> mine within 200 feet of any structure until the Division has <br /> reviewed and approved the exhibit . <br /> 22. In addition, please demonstrate how the revised final slope configurations are compatible <br /> with the approved post-mining land use which will support rangeland. Please note, C.R.S <br /> 34-32.5-116(4)(n) states if the operator's choice of reclamation is for range, the affected <br /> lands shall be restored to slopes appropriate with the proposed land use that shall not be <br /> too steep to be traversed by livestock. <br /> At this time there are large sections of natural near vertical <br /> sandstone walls all over the property and in the canyons that <br /> livestock have not had trouble traversing in the past . While the <br /> near vertical sandstone faces are not ideal rangeland, the slope <br /> areas in the mine will amount to 6 . 3 percent of the total <br /> reclaimed area. <br /> 11 <br />