2004-04-26_REVISION - M1978056 - Laserfiche WebLink

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expected at any one time throughout the remainder of the operation in terms of acreage and linear feet of pit disturbance, and acreage of other disturbances. (As an alternative, VCI may propose the number of linear feet of pit disturbance and acreages for all existing and planned disturbances (185.23 acres of affected land) minus disturbed slopes and/or acreage already reclaimed to desired final reclamation conditions and deemed ready for reclamation responsibility release by the Division of Minerals and Geology.) Pease respond. Exhibit L -Reclamation Costs, details the extent of disturbance for each area shown on Exhibit C -Mining Plan Map. As indicated in the summary overview on page 1 of Exhibit L, Maximum Disturbance was reached shortly before the succession of operators in 1999. Since each act of extraction and concurrent grading and reclamation is trending to lower the reclamation and extent of disturbance provided for under each area, the actual liability will progressively decrease from that detailed at the time of the Amendment submittal, and can be reassessed at the completion of each phase. Since maximum disturbance is defined per area shown on Exhibit C - it is difficult to reassign and reorder the magnitude of disturbance as requested. The point of the Exhibit L calculations is to create order to nearly 20 yeazs of operations for which no order or sequence of extraction was established. We respectfully request the Division to follow the sequences and areas defined under Exhibit L -and trust you will see that each area of disturbance can be tracked progressively from this point forward. You will note first that unaffected lands, in-situ and stockpiled soils, Facility locations and access roads were distinguished from all other affected lands. Then Tracts A through D were detailed. All aspects of accounting were then detailed, including perimeter areas of definable slopes for tract D and the ponded areas of Tract C. These summaries attempt to distinguish definable aeeas used later in financial warranty determinations. The Exhibit breaks down the application of exposed ground water to the approved SSP. This component relates both extraction and fill activities over time to meet the water obligations of the location. Water relates extraction in each area over time. Following Water, each definable area is accounted for in detail for costs related to Dewatering, Grading and Soil Preparation. Soil demand and Recoiling of each Area is followed by an examination of Revegetation costs, followed by related mobilization and demobilization costs. This examination per area is a study of mining and reclamation over time based upon the current level of distwbance, as the Maximum level of disturbance. As each vear of minin¢ and concurrent reclamation progresses, the actually financial warranri liability of the 6. In conformance with Rule 6.44, please clarify the current or planned volume, whichever is greater, of stockpiled overburden that will need to be backfilled into the pit during final reclamation, and provide the average push/haul distance to move the stockpiled overbwden into the pit. (The volume of overburden that will be used to backfill Tract D may be excluded from this volume estimate.). Please clazify. None. No stockpiled overburden will be necessary to the establishment of completed slopes. All calculations were based upon a cut, fill, or cut/fill basis using a volume graphic applied to each unique area of the mine. For example, while the complete fill of Area D is provided for in the mine plan, grading of Area D is also included in the calculations, as a cost above and beyond to provide for this contingency should default occur prior to completion of the fill. The grading along the existing pond, along with related dewatering costs, is also provided for on the basis of a Varra Companies, Inc. M1978-056 Durham Sand & Gravel Pit - 2003 Amendment - Monday 26 Apri12004 reply to correspondence from the Colorado Division of Minerals and Geology of 6 January 2004.