2023-02-02_PERMIT FILE - M2022013 (12)

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Raptor Materials Second Adequacy Response Raptor have provided additional information in response to this request to the Weed Management Plan section in revised Exhibit I/J (page 7, Footnote 2). 35) The Backfill Notice must state the maximum quantity of inert fill that will be stockpiled on the site at any given time. This information is necessary to calculate the required financial warranty amount. Will buildings or other structures be constructed on backfill areas? If so, how will the material be placed and stabilized to prevent settling and voids? Raptor Materials First Adequacy Response Revisiting the Backfill Notice located at the back of Exhibit E: Reclamation Plan, it is noted that a Backfill Notice is required to address specifics in placement of external materials "generated outside of the approved permit area". The notice in this application however seeks to serve both that purpose and address the use of backfill generated within the MLRB permitted area. The use of on-site fill is from extracted or processed reject materials, field fit at the time, depending upon the state of Operations. This is not predictable, but only inert fill, whether found on-site, or imported, will be utilized. There is no means to forecast fill material produced, but the use and location will be reported in required OMLR Annual Reports and addressed as necessary with adjustment to the financial warranty. This is an established practice with the OMLR from prior operations. As to methodology and avoidance of instability of fill areas, the Notice states: `All backfill material will be placed with sufficient fines to minimize voids and settling of backfilled areas and slopes . There are no known or expected acid forming or toxic producing materials or refuse at this location, nor will materials known to possess such qualities be knowingly utilized for fill . Any other refuse or reject materials that do not meet the definition of inert and requiring removal and disposal will be placed in closed containers and taken to an appropriate landfill for disposal, unless it is otherwise `inert, ' per Rule 3.1 .5(9) , of the OMLR Rules and Regulations. ' Division Second Adequacy Comment No additional response is required from RM, but the Division would like to make two comments for the record. The purpose of the Backfill Notice is to address imported material, not material that originates within the permit area. Also, if 401Page Correspondence to the Colorado Office of Mined Land Reclamation —Reply to Rob Zuber,EPS—Adequacy Letters of 24 June and 5 August 2022;in the matter of the Two Rivers Sand,Gravel and Reservoir Project—M2022-013.