2018-10-16_PERMIT FILE - M2018039 ‎(2)‎

• Permit No: M2018039
• IBM Index Class Name: PERMIT FILE
• Doc Date: 10/16/2018
• Doc Name: Adequacy Review Response
• From: Blue Earth Solutions
• To: DRMS
• Email Name: JLE
• Media Type: D
• Archive: No

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SOLUTIONS
October 15, 2018
Colorado Department of Natural Resources
Division of Reclamation, Mining and Safety
Attn: Mr. Jared Ebert
1313 Sherman Street; Room 215
Denver CO, 80203
RE: Response to Adequacy Review Comments for North Weld County Water District,
Lamb Lakes, File No. M-2018-039
Dear Mr. Ebert:
The following discussion and attachments are submitted on behalf of our client, North Weld
County Water District, in response to the Adequacy Review comments prepared by the Division
of Reclamation, Mining and Safety (the Division) dated September 11, 2018 for the Lamb Lakes
site Regular (112) Operation Reclamation Permit application. The information and discussion
below address each comment as it was presented by the Division.
Rule 6.4.3 —Exhibit C—Pre-mining and Mining Plan Map(s) of Affected Lands
1. The topographic lines on Exhibits C-5, C-6, and F-1 have been corrected. Please see the
revised exhibits in Attachment A.
2. The Fort Collins Irrigation Canal Ditch and Larimer and Weld Irrigation Ditch have been
labeled on Exhibit C-6. Please see the revised Exhibit C-6 in Attachment A.
Rule 6.4.4—Exhibit D—Mining Plan
3. According to the 1987 Home Office Pit Amendment by Sterling Sand & Gravel
Company, topsoil and overburden was removed from the site during mining. The
amendment suggests that the site originally consisted of approximately 1-foot of silty
topsoil and from 1.5 to 3 feet of silty/sandy clay overburden. However, the amendment
and other documents also indicate that only enough quality topsoil was stockpiled to
replace an average of 8 inches during reclamation. Site observations confirm that a
relatively thin layer of topsoil exists on the site.
The applicant shall salvage all available topsoil on-site, likely less than 8 inches, prior to
additional mining and reclamation disturbances. It is assumed that significant quantities
of overburden do not exist on-site. Overburden, or "weathered bedrock", which could
have similar properties to the original clay overburden, may be encountered during
additional excavation on the lake bottoms. Layers of decomposing organic material may
also be encountered during lake dewatering and excavation. However, at this time the
potential quantities of these materials are not known. If these materials are available, and