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c <br /> r�nE�Ta� <br /> Department of Energy <br /> tr Washington, DC 20585 <br /> May 22, 2025 <br /> OLM-KC-2025-040 <br /> Mr. Ben Hammar, Environmental Protection Specialist RECEIVED <br /> Colorado Division of Mining, Reclamation and Safety <br /> 1313 Sherman Street, Room 215 MAY 2 7 2025 <br /> Denver, CO 80203 <br /> DIVISION OF RECLAMATION <br /> Subject: The Lakewood Brick and Tile Company <br /> MINING AND SAFTEY <br /> Construction Materials Regular(112) Operation Reclamation Permit <br /> Application Amendment—The Church Pit File No. M-1979-045 <br /> Objection and Comment <br /> Dear Mr. Hammar: <br /> The U.S. Department of Energy(DOE) Office of Legacy Management provides the <br /> following objection and comments for your consideration regarding the Permit <br /> Amendment for the Church Pit submitted by the Lakewood Brick and Tile Company on <br /> April 25, 2025. DOE currently owns the land where the current Permit is placed and <br /> opposes the proposed Amendment that would allow for Developed Water Storage at the <br /> Church Pit. The objection is based upon the scope of the Rocky Flats National Wildlife <br /> Refuge Act of 2001 (the Refuge Act) and its intended purposes. The current usage of this <br /> property as enacted, raises concerns that a developed water storage feature could impact <br /> the cleanup remedy at the Rocky Flats Site. <br /> A water storage feature located upstream of the Rocky Flats Site has the potential to <br /> affect the existing remedy designed to protect human health and the environment. This <br /> could include mobilizing contamination, increasing the volume of water flowing through <br /> the on-site treatment systems, and altering the hydrologic balance of the area, which may <br /> lead to slope instability. The reclamation plan submitted by the operator has not <br /> demonstrated how it will minimize disturbances to the current hydrologic balance at the <br /> Rocky Flats Site. <br /> Additionally, the Refuge Act designates the Church Pit to remain under federal ownership <br /> indefinitely, unless Congress decides otherwise. The Rocky Flats National Wildlife <br /> Refuge Comprehensive Conservation Plan and Environmental Impact Statement <br /> (CCP/EIS), issued in September 2004, outlines the following purposes for the Refuge: <br /> 1. Restoring and preserving native ecosystems. <br /> 2. Providing habitat for, and population management of native plants and <br /> migratory and resident wildlife. <br /> 3. Conserving threatened and endangered species. <br /> 4. Offering opportunities for compatible scientific research. <br />