Laserfiche WebLink
<br />BEFORE THE COLORADO MINED LAND <br />RECLAMATION BOARD <br />1313 Sherman Street <br />Denver, Colorado 80203 <br />IN THE MATTER OF REASON TO BELIEVE VIOLATION <br />EXISTS PERMIT M-1978-052, MOBILE PREMIX <br />CONCRETE, INC., A SUBSIDIARY OF LAFARGE <br />NORTH AMERCIA INC. <br />AFFIDAVIT OF JOHN DURHAM <br />STATE OF COLORADO ) <br />ss. <br />COUNTY OF ADAMS ) <br />John Durham, being first duly sworn upon oath deposes and states as follows: <br />1. From and after 1974 to the present, I have been employed and worked at <br />what is now known as the Howe Pit. In 1974, the Howe Pit was owned and operated by <br />Consolidated Rock Company. In 1977, the Howe Pit was acquired by Mobile Premix <br />Concrete, Inc., ("MPC"). For the majority of this time, I have served as the Foreman at <br />the site. <br />2. Although I was not involved directly in its installation, I am aware that in 1995 <br />MPC personnel placed a concrete rubble structure at a point where the then relocated <br />Bull Seep discharged to the Bull Seep Slough. MPC personnel used 988 front-end <br />loaders to transport the concrete rubble from the concrete plant located on the site to <br />the point where the structure was installed. <br />3. I have also personally witnessed backwater conditions on the Howe Pit site. <br />This is when water from the South Platte River backs up the Bull Seep Slough and then <br />overtops and flows into the northern most mine pit at the site. <br />FURTHER AFFIANT SAYETH NOT. <br />ohn Durham <br />