2021-01-21_PERMIT FILE - M2020053

• Permit No: M2020053
• IBM Index Class Name: Permit File
• Doc Date: 1/21/2021
• Doc Name: Adequacy Review Response
• From: Environment, Inc.
• To: DRMS
• Email Name: BFB
• Media Type: D
• Archive: No

•
Sri ro a C.
LARRY E.O'BRIAN 7985 VANCE DRIVE,SUITE 205A
FOUNDER ARVADA,COLORADO 80003
STEVAN L.O'BRIAN 303-423-7297
PRESIDENT FAX [phone]
January 15, 2021
Mr. Brock Bowles
Division of Reclamation, Mining and Safety
1313 Sherman St, Suite 215
Denver, CO 80203
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Dear Mr. Bowles 0111SIONOF
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RE: Logan County — Barkley Pit i01V
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Adequacy Response 01 — M-2020-053
On behalf of my client Logan County, I am responding to
your adequacy review letter dated December 23, 2020 . I have
included your review points that need to be addressed in the
order presented in this cover letter so the questions and
answers will be in the same document for easy future reference.
6.4.4 EXHIBIT D -Mining Plan
1. On page D-2, 3rd paragraph, it states that the only structures are the fence owned by Barkley on
the west side and along CR 10. Map Exhibit C and Google Earth show a fence along the southern
border. This fence line is on the property boundary with the adjacent landowner, Brekel. Please
update the text in this section to include the fence line as a structure.
When the permit area was surveyed the only fence noted on the survey was the western one along the
west side of the south line. The Google Earth photo I looked at shows a distinction between the
fields, but I think this is due to the nature of the crop litter left after harvest. Jeff Reeves says
that the only fence on the south line is a short 240 foot section on the west end as shown on the
maps. On page 0-2 the text explains the fence and how it relates to the permit lines so there is no
need to add more text.
2. Western wheatgrass is proposed as a cover crop on topsoil stockpiles. It's the Division's experience
that western wheatgrass is slow to establish and does not create an even cover on topsoil piles. It is
suggested that other species be included to protect the piles: a sterile oats or triticale as a first year
cover crop and alfalfa which can establish faster than wheatgrass and can last several years.
Alfalfa has the added benefit of fixing nitrogen helping to maintain the topsoil.
Thank you for the suggestion,but we believe the use of the western wheatgrass will work best for this
site. In the Logan County vicinity topsoil piles tend to acquire a heavy cover of tumbleweeds the first
year but thereafter the western wheatgrass takes over for the long term. Also due to the small size
of the area initially disturbed the stockpile will be small and the outlay for a specially seed mix is not
practical that might get used every 3 to 4 years. The western wheatgrass is easy to obtain in relative
small quantities like what mould be needed at this mine.