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

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RE: J-2 Contracting Company—DPG Pit—Permit No. M-2019-028 112(c) Permit Application Adequacy Review No. 1 Response 8126119 -14- e. While the operator provided a copy of the Certified Mail Receipt for Kerr-McGee Oil & Gas Onshore LP, the Division could not find the associated structure agreement. Please provide a copy of the structure agreement that was mailed to Kerr-McGee Oil & Gas Onshore LP. f. Until all structure owners have been identified on the Exhibit C maps, and the structure owner list (requested in item no. 52 above) has been provided, the Division cannot confirm that structure agreements have been attempted for all applicable structure owners. Please be sure that proof of such an attempt is provided for all permanent, man-made structures (not owned by J-2 Contracting Company) which are located on or within 200 feet of the proposed affected lands. Response: The certified mail receipts were sent along with the letters to match the receipts in response to your e-mail on 7112119. Attached is a structure agreement letter for the DPG owned structures stating that J-2 Contracting Company can mine within 200 feet and also remove structures where needed to mine. 54) The application includes a Slope Stability Report (report) prepared by J&T Consulting, Inc., intended to satisfy the requirements of Rule 6.4.19(b) in the event that structure agreements cannot be reached. The Division has the following comments/questions regarding this report: a. No executed structure agreements have been submitted at this time for structures located on or within 200 feet of the proposed affected lands. Therefore, pursuant to Rule 6.4.19(b), the applicant shall provide an appropriate engineering evaluation that demonstrates that such structure shall not be damaged by activities occurring at the mining operation. However, the report submitted does not address all structures identified on the Exhibit C maps. Please be advised, for all structures located on or within 200 feet of the proposed affected lands, which the operator is unable to obtain an executed structure agreement, an appropriate engineering evaluation must be provided which demonstrates such structures will not be damaged by activities occurring at the mining operation. b. The report does not suggest setbacks for several structures shown to be located within the proposed affected lands on the Exhibit C maps, including gas lines, gas tanks, fence lines, buildings, a pond, and Holly Avenue. Additionally, proposed setbacks for these structures are not shown on the Exhibit C maps. In fact, it appears the operation will mine through most of these structures. Please be advised, for any structures not owned by J-2 Contracting Company, which will be affected by the operation, the Division must receive a notarized agreement between the operator and the structure owner acknowledging as such. c. The report states the design criteria used to establish the desired minimum safety factors for the proposed project include a Factor of Safety (FOS) of 1.3 for static conditions, and a FOS of 1.0 for pseudo-static conditions. The policy of the Mined Land Reclamation Board for Factors of Safety for Slope Stability/Geotechnical Analyses (see enclosed policy) recommends the following minimum FOS for non- critical structures (e.g., fences): a FOS of 1.3 for static conditions and a FOS of 1.15 for analyses using seismic parameters; and for critical structures (e.,q residences, utilities, dams, pipelines, irrigation canals, public roads): a FOS of 1.5 for static conditions and a FOS of 1.3 for analyses using seismic parameters. Please be V 305 Denver Avenue—Suite D-Fort Lupton CO 80621 •Ph: 303-857-6222•Fax:303-857-6224