Laserfiche WebLink
<br />Division of Minerals <br />Attn: Me. Kamnikar <br />September 26, 2000 <br />Page 2 <br />u <br />and Geology <br />My comments are as a result of inquiry and investigation by one of <br />my clients, Brenda Gallagher, who is a geophysical engineer and has <br />taken an active interest in the permitting process. As I am sure <br />you can see from the following comments, as well as the enclosed <br />detailed June 30, 2000 report by the staff to the Board of the <br />Arapahoe County Commissioners, much constructive work and thought <br />has already occurred into the project by other governmental <br />agencies. <br />Therefore, in accordance with Senate Bill 95-156, Section 34.32.5- <br />112 of the Colorado Revised Statutes and the Colorado Mined Land <br />Reclamation Board, Construction Material Rules and Regulations, we <br />would request that the above-referenced application be revised to <br />address the following concerns for improved mitigation and <br />reclamation. Also please take this as written objections and a <br />petition for a hearing under C.R.S. 34-32.5-114. My clients' <br />comments follow: <br />1. Topsoil. The actual topsoil depth at the site is only 4-6" <br />per Gene Backhaus/NRCS West Arapahoe SCD, not "...from 6-12 <br />inches in depth" as stated in Exhibit "D"(F)(i). As the site <br />is to be returned to dryland agricultural use after mining, <br />the soil depth is insufficient to permit the removal of <br />topsoil from the site for resale per Robert Zebroski/State <br />Soil Conservation Board and Daniel Parker/Consultant (Rules <br />3.1.1(1) and (2), 3.1.9(1) and (6), 6.4.4 (g) and 6.4.9(1)). <br />References to the sale or resale of topsoil should be <br />eliminated in Exhibits "C" (e.g., sheet 1/4, MINING, <br />EXCAVATION AND LAND LEVELING OPERATIONS, Section 4, ¶ 2 and <br />5) and "D". <br />Reference Exhibits "C" (e.g., sheet 1/4, MINING, EXCAVATION <br />AND LAND LEVELING OPERATIONS, Section 4, ¶ 9) and "E", <br />stipulate that sand mixed w/sludge is an unacceptable topsoil <br />substitute or amendment (reference Gene Backhaus). Compost <br />and/or chemical fertilizers mixed with topsoil are acceptable <br />amendments (Rule 3.1.9(6) and (7)). <br />2. Water Usage and Retention. Reference Exhibits "C" (i.e., <br />sheet 1/4, WATER AND SEWER USAGE, Section 9) "D" and "E", <br />include estimates of project water requirements and annual <br />