2018-12-19_REVISION - M2006081

• Permit No: M2006081
• IBM Index Class Name: REVISION
• Doc Date: 12/19/2018
• Doc Name: Adequacy Review Response
• From: Gagliano Engineering
• To: DRMS
• Email Name: ERR
• Media Type: D
• Archive: No

compared to the background image on the maps. Please depict the correct location
of this canal road and re-submit these maps. Location of access road has been
corrected. See included maps.
EXHIBIT C - Pre-mininiz and Mining Plan Mav(s) of Affected Lands (Rule 6.4.3):
5. None of the Exhibit C Maps contain information regarding structures as required
by Rule 6.4.3(g). Please revise one of the Exhibit C Maps or submit a new Exhibit
C Map which identifies the location of all permanent man-made structures
contained on the area of affected lands and within 200 feet of the affected lands.
The structure owner's name and type of structure must also be identified on the
map. Labels added to Exhibit C Maps.
EXHIBIT D - Mining Plan (Rule 6.4.4):
6. The Applicant proposes to have a phased mining/bonding operation. Please
commit to contacting the Division for approval prior to advancing into an un-
bonded phase. The request will include the estimated reclamation costs that would
be required for opening the additional phase. The Division will review and
calculate a new finical warranty amount, issuing a Surety Increase revision if
necessary. Once the additional amount is posted the Operator will be approved for
the new phase. Please note, the Applicant may submit a Surety Reduction request
for specific reclamation tasks completed in previous or an Acreage Reduction
request for portions of the affected lands where final reclamation has been
achieved. Released amounts of financial warranty from these requests could be
used to help off-set reclamation costs associated with the new phase. The
Applicant commits to notifying the Division prior to expanding into
additional phases and adjusting the Surety as needed.
EXHIBIT E - Reclamation Plan (Rule 6.4.5):
7. The Applicant states the proposed reclamation plan is based on the Reclamation
Plan developed by the District Conservationist of the NRCS Pueblo Field Office.
After a review of the proposed reclamation plan and the NRCS Plan, the Division
has discovered a discrepancy between the plans regarding subsoil. The proposed
reclamation plan is silent on the subsoil replacement while the NCRS Plan
recommends at least 18 inches of subsoil to be replaced prior to topsoil
replacement. Typically, the Division has approved reclamation plans for similar
operations in the area which utilize overburden and processing fines as the subsoil
component. Please address this discrepancy and either commit to implementing
the NRCS recommendations or submit an appropriate technical justification for
the deviation in the plan. 6.4.5 (2) has been revised to include 18" of subsoil.
8. Similar to Adequacy Item No. 7, the Division discovered a discrepancy between
the plans regarding topsoil replacement. The proposed reclamation plan states
topsoil will be replaced at a depth of 1" to 6" while the NRCS plan recommends
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