2020-03-16_INSPECTION - M1974069

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1P I5. Photo 20 from the inspection report shows view looking p p west over Cell 18. We MN 0 1111,13-3‘ estimate that the channel around the perimeter of Cell 18 is working as L OVELAN D designed and naturally drains ground water to Cell 14. Figure 1 attached, shows Cell 18 has 0.3 acres of exposed water surface. READY m Ix 6. Figure 1 shows the exposed surface area for all exposed water in Cells 13, 14, 15, 18, and 20,that are augmented under 00CW142. Their respective areas CONCRETE are as follows: Cell/Pit No. Area Exposed Status Water Surface PO BOX 299 13 15.5 acres Reclaimed and released LOVELAND, CO 80539 14 13.5 acres Backfilling/Reclaiming 15 5.9 acres Reclaimed and released OFFICE 970.667.2680 18 0.3 acres Substantially reclaimed FAX 970.667.0092 20 8.5 acres Reclaiming Total Exposed 43.7 acres Less than 52.29 allowed 7. LRM agrees the west end of Cell 20 will be gradually filled with wash fines from our gravel plant and the reclamation plan estimates that up to 4.5 acres may be filled with fines; not the 11 acres we believe was mistakenly used in Task 21. Final Cell sizes called out in the reclamation plan are determined using the best information available at the time the reclamation plan was established. LRM believes we have taken appropriate measures to insure there is no risk to the Division should final Cell sizes vary from those estimated in the Reclamation Plan and that we have provided the necessary safeguards to allow some degree of flexibility to reflect the actual quantities of alluvium,overburden and processed wash fines produced. LRM does not agree that the Division needs to require bonding for 4.5 acres of potential backfill because the total exposed area of both Cells 18 and 20 (8.8 acres) is augmented and is currently under 12.02 acres,the total exposed surface area of the entire Larimer Pits is under 52.29 acres, and there is no potential for an additional exposure of 8.6 acres of water surface.There is absolutely no exposure or damage to the Division if Cell 20 were to remain its current size as there is more than adequate augmentation water authorized by both 00CW142 and Well Permit 69035-F to permanently augment the current exposed water surface. The language in 00CW142 is purposeful in its intent to allow flexibility within the mining boundary to allow for the anticipated variances in each Cell size that inevitably occur during mining. Therefore, backfilling Cell 20 with the only intent of insuring its final size becomes 4 acres is pointless. A much more appropriate bond amount would be seeding of the current 2 acres of the regraded area around Cell 20 in addition of future topsoiling and seeding of 4.5 acres should Cell 20 actually be backfilled to reduce it in size to the 4 acres called out in the reclamation plan. Our revised calculations for Task 021 is$0.00,for Task 022 is$4,981,and Task 023 is $14,618. 2IPage