2019-11-12_REVISION - M2004044 (13)

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Jared Ebert November 8, 2019 Page 6 of 6 ii. DRMS Response: Based on the easement deed and agreement submitted by the applicant, it does not appear a commitment was made by the Operator to compensate Todd Creek Metropolitan District for damages to their structures. Al will need to address the adequacy review issues identified in the enclosed Memorandum regarding the geotechnical stability analysis or provide a complete structure damage agreements for the structure in question. iii. Al Response: The agreement with the Todd Creek Metropolitan District allowed for encroachment up to twenty feet from the water line. As shown in the stability analysis (attached), we elected to offset the limit of mining excavation 45 feet from the Todd Creek easement boundary. The analysis demonstrates that the factor of safety with this offset exceeds the DRMS requirements. iv. DRMS Response (3): The Division acknowledges that Al has complied with this condition. Al Response: So Noted. In addition, our conversations with the Adams County Commissioners have resulted in a change to the phasing within the permit boundary. We have revised the maps and Exhibits to update the phasing. An updated Exhibit L reflecting the phasing change is attached. We reviewed the Reclamation Cost Estimate in the context of the revised phasing and determined that the estimate as attached represents the maximum level of disturbance on the site. As a result of the revised phasing plan, there will be no immediate dewatering associated with mining south of HWY 7. As you requested, we have entered into the agreements with the well owners adjacent to the south parcel. However, due to the phasing change, the South Parcel will be the last phase of the project and the pre-mitigation measures associated with the South Parcel will not occur immediately. We will install the pre-mitigation measures as outlined in the agreement six months prior to commencement of any mining activity on the South Parcel. We will continue to collect monitoring well information until it is necessary to implement the pre- mitigation measures in anticipation of mining the South Parcel. Please accept this information for review. Thank you for your consideration. Please contact us if you need additional information to complete your review. Sincerely, CU � 'F�g Christine Felz, Land and Environment Manager Aggregate Industries-WCR, Inc. Attachments: Attachment 1 —Executed agreements with affected well owners Attachment 2—City of Thornton Legal Right to Enter Attachment 3—Revised Exhibit C Attachment 4— Revised Exhibit F Attachment 5— Revised Exhibit G Water Information Attachment 6—Revised Exhibit L Reclamation Cost Attachment 7—Stability Memo Update Aggregate Industries—WCR,Inc 1687 Cole Blvd Suite 300 Golden,CO 80401