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Jr As with Cell 20, because is no potential for Pits 13, 14, 15, 18, 20 to expose an <br /> MIN 0 t� additional 8.6 acres of water surface there is absolutely no risk or damage to the <br /> L OVELAN D Division if Cell 14 were to remain at its current size and configuration. There is more <br /> than adequate augmentation water authorized by both 00CW142 and Well Permit <br /> R EADY•MIX 69035-F to permanently augment the current exposed water surface and any potential <br /> future exposures. The language in 00CW142 is purposeful in its intent to allow <br /> CONCRETE flexibility within the mining boundary to allow for the anticipated variances in Cell <br /> sizes and exposed water surfaces. Therefore, requiring a bond for additional backfill in <br /> an area of Cell 14 that currently meets the requirements of the Reclamation Plan is not <br /> needed. <br /> PO BOX 299 <br /> LOVELAND, CO 80539 A much more appropriate bond amount would be topsoiling and vegetation of the <br /> current backfilled area of 11.6 acres in Cell 14 as calculated by the Division, knowing <br /> OFFICE 970.667.2680 that this area will not be exceeded. <br /> FAX 970.667.0092 <br /> Cell/Pits 5 and 6 We believe Tasks 009 and 012 in the Divisions revised bond estimate <br /> are incorrect. Our reasoning is outlined below. <br /> 1. After reviewing the Reclamation Plan submitted in 2015 and 2006 LRM agrees <br /> the plan calls for an estimated 2 acre ft of exposed water surface in Cell 5, and <br /> an estimated 1 acre ft of exposed water surface in Cell 6. <br /> 2. Cells 5 and 6 operated as silt ponds and as a result the ponding in Cell 5 is <br /> extremely shallow. Figure 1 confirms this. LRM believes Cell 5 is <br /> approximately 8 feet maximum. <br /> 3. LRM's calculations show that Cell 5 only needs to be backfilled 0.75 acres to <br /> reach 2 acres final size. However, Cell 5 was mined pre 1980 and does not <br /> need to be augmented. In addition, as shown in Exhibit B of 00CW142, Cell 5 <br /> was also identified for augmentation under W-7412 with a projected final <br /> water surface area of 3.39 acres. <br /> 4. Cell 6 is essentially silted in with some limited water exposure around the <br /> perimeter trenching. Though the exposed water surface does not occur in one <br /> location but throughout the cell, LRM's calculations show there is little to no <br /> backfill required to reduce the actual exposed water surface to 1 acre. It has <br /> filled in with cattails and has a nice stand of willows growing along the south <br /> bank. Cell 6 was mined pre 1980 and does not need to be augmented. In <br /> addition, as shown in Exhibit B of 00CW142, Cell 6 was also identified for <br /> augmentation under W-7412 with a projected final water surface area of 2.27 <br /> acres. <br /> LRM agrees that some additional topsoil and seeding needs to be placed at Cells 5 and <br /> 6 in order to reach an acceptable reclamation standard. Estimated final exposed <br /> water surface areas as called out in the Reclamation Plan are estimates only, using the <br /> best available engineering information at the time. Because there is no potential for <br /> either Cell 5 or 6 to expose additional water surface that will exceed that allowed in <br /> W-7412 there is absolutely no exposure or damage to the Division if Cells 5 and 6 were <br /> to remain at their current size and configuration. Therefore, requiring a bond for <br /> additional backfill in Cells 5 or 6 is not needed. <br /> Wage <br />