2019-08-29_PERMIT FILE - M2019028 (3)

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RE: J-2 Contracting Company-DPG Pit-Permit No. M-2019-028 I I2(c)Permit Application Adequacy Review No. 1 Response 8126119 -12- proposing to have DPG Farms, LLC pledge their Patterson Ditch shares to the mine permit for use in augmenting for the groundwater depletions should the slurry wall not get installed for Phase 1. In addition to the shares an additional $150,000 is proposed to be bonded for to cover the administration costs (water rights engineering and attorney fees) for changing the shares to augmentation uses from irrigation through the Division of Water Resources and Colorado Water Court. If this is acceptable DPG Farms, LLC will provide an affidavit for approval from the Division of Water Resources dedicating the Patterson Ditch shares to the mine. This combination of water shares and bonding will only be valid for Phase 1 of the mining. Additional Phases will require bonding for the slurry wall construction and water shares will be turned back over to DPG Farms, LLC once approval of the slurry wall for Phase 1 has been provided to the DRMS. 46) Please submit an Exhibit L map showing the proposed scenario for the reclamation bond. This map should depict the site at the point of maximum disturbance (as proposed at this time), and should correlate with the bond estimate provided. Please be sure the map shows expected locations of topsoil and overburden stockpiles at that point in time, so the Division can estimate haul distances. Response: The maximum disturbance has been provided in the revised Exhibit L bond calculations for the Phase 1 mining. An Exhibit L map has also been provided to provide more detail of the total disturbed area for the phases of mining. 47) Please provide costs for installing all components of the proposed inlet/outlet structures for the proposed point of maximum disturbance. For example, if the operator is proposing to be bonded at this time for only the Phase 1-2 Pit/Reservoir 1, then only the applicable inlet/outlet structures proposed for that reservoir would need to be included in the bond estimate at this time. Response: The revised Exhibit L bond calculations have been updated to include the costs for the riprap lined spillways associated with each phase. 48) Please be advised, the Division must hold 100% of the costs for installing the 1 st slurry wall enclosure until the operator demonstrates the liner has been approved by the SEO, at which time, the operator may request a surety reduction to include 20% of the construction costs for this enclosure. The Division must hold a minimum of 20% of the construction costs for each completed and SEO approved slurry wall enclosure until the reservoir has been released from the permit. Please confirm the 1 st slurry wall enclosure will be installed around Phases 1 and 2, identified as Reservoir 1 on Exhibit F-1 Reclamation Plan Map. Additionally, please be sure the bond estimate includes 100% of the costs for installing at a minimum the Vt slurry wall enclosure. Response: The revised Exhibit L bond calculations include bonding for the slurry wall around Phase 1. The bond will be increased to include Phase 2 with a Technical Revision prior to starting mining in Phase 2. 49) The summary of unit costs specifies a dollar amount per foot for installation of each of the proposed five phases of slurry wall installation, including 0-50 feet at $3/foot, 51-70 feet at $4/foot, and 71- 95 feet at $13/foot, and provides an estimated total cost per linear foot for each of the five phases. However, the Division is unable to confirm the total cost for each phase of slurry wall construction without knowing the depths of installation for each phase. Please provide the average depth of installation for each slurry wall enclosure. Response: The average depth of slurry wall installation for Phase 1 is 80 feet. The average depth of slurry wall installation for Phase 2 is 85 feet. The average depth of 4, 305 Denver Avenue-Suite D•Fort Lupton CO 80621 •Ph: 303-857-6222•Fax: 303-857-6224