2019-08-12_REVISION - M2013066

• Permit No: M2013066
• IBM Index Class Name: Revision
• Doc Date: 8/12/2019
• Doc Name: Adequacy Review Response
• From: Arboles Sand & Stone, LLC/Wasteline Inc.
• To: DRMS
• Type & Sequence: TR1
• Email Name: LJW
• Email Name: THM
• Media Type: D
• Archive: No

WASTE-1-UNIE M1V.J o
P.O. Box 3471 Rapid City, SD 57709-3471 [phone]-P.O. Box 88 Cortez, CO 81321-0088
3201 Latham Ave Evans, CO 80620
E-mail:[e-mail]
07 August 2019
SUBJECT: M2013-066 LOBLOLLY PIT SECOND REVISED ANNUAL REPORT MAP AND
ADDITIONAL INFORMATION FOR TECHNICAL REVISION APPLICATION
Colorado Division of Reclamation Mining and Safety RECEIVED
ATTN: Lucas West
1313 Sherman Street Room 215 AUG 12 201
Denver, CO 80203
DIVISION OF RECLAMATION
Dear Mr. Lucas: MINING AND SAFETY
This letter and its attachments address specific items in the Division's adequacy review letter of
08 July 2019.
1. Please find the attached map showing the status of mining and reclamation at the Loblolly Pit
corrected to include areas as of April-May 2019, replacing both the maps submitted for the
annual report and those submitted by letter of 24 June 2019. Only the map for the North Parcel
is submitted, based on the information you provided in your adequacy review letter dated 12
July 2019, with the maps now available at the Archuleta County GIS website. Those maps were
not available as of the submittal of 24 June 2019, and the base FEMA satellite photos were
apparently incorrectly identified as being taken in April 2019. 1 have been unable to identify the
date(s) of the maps currently on the County GIS website, but they appear to be (based on water
levels and areas affected) taken sometime in April-June 2019. They are NOT orthophotos and
appear to have some slight distortion, and also have parcel lines shown incorrectly (as
demonstrated that the parcel lines do not match terrain features known to be located
on/immediately adjacent to parcel lines as determined by survey of the site.
This revised map was used to revise a table of areas, and forms the basis for the revised cost
estimate for the Technical Revision. AutoCad was used to measure distances and areas.
2. As discussed, it is possible to accurately and completely excavate the construction materials
and shape the ponds, without dewatering. There are several methods to determine the slope of
the lakebed of all ponds in the north parcel (as was done in the south parcel) to demonstrate
that the maximum slope of the lakebed to a depth of 15 feet below the ordinary highwater mark
(HWM) of the ponds is 3H:1 V. This has been done at many permitted construction materials
operations in Colorado and elsewhere.
There are several methods that can demonstrate that (a) the maximum depth of the pond at 45
feet of the shoreline is no more than 15 feet and (b) the slope is in compliance (3:1 or flatter)
with the Construction Materials Rules. For purposes of estimating costs, it is proposed (working
with a local (Durango), third-party surveying firm) that it be done using a small boat with a grid
established on-shore, and a long level staff (leveling rod). It is important to again note that the
water level in the ponds is not static, and rises and falls with the water levels in the Piedra River,
to which they are connected hydraulically, as these ponds are located within the alluvial aquifer.