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2007-06-19_REVISION - M1986015
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2007-06-19_REVISION - M1986015
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Last modified
6/15/2021 5:42:24 PM
Creation date
11/21/2007 11:59:57 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1986015
IBM Index Class Name
Revision
Doc Date
6/19/2007
Doc Name
Response to Adequacy Ltr.
From
Southwestern Ecological Services
To
DRMS
Type & Sequence
AM3
Media Type
D
Archive
No
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Page 2 <br />Adequacy Response Letter <br />Pueblo East Pit <br />June 19, 2007 <br />turbulence. With the streambank strengthening proposed, the barrier berm would not need to be large ox <br />particularly strong. As fax as bonding is concerned, the material contained in this berm would eventually be <br />taken to Phase 1 for backfilling ox simply pushed down over the fmished slopes of Phase 2. In the event a party <br />who desired to use the site fox a reservoir wished to maintain (or strengthen) the berm then that would be their <br />option after release of the site through either a succession of operator, full release upon completion of the <br />reclamation, ox some other mechanism. If the altematve revegetation plan was implemented for Phase 2 then <br />this berm would not likely be removed as it would provide some protection for the unfilled pit that would <br />remain in that option. <br />5. Item II E - I think there is a misunderstanding here. Your quote from the plan is incomplete. The actual <br />wording is "Gradual backfilling of the initial mining area in Phase 2 will use a mixture of ..." (Italics indicate the <br />missing portion of your quotation.) The only area in Phase 2 that will be backfllled will be the small initial <br />mining area in the northeast corner and outside of the slurry wall. No other backfilling will occur in Phase 2. <br />Your observation that the Emal pit slopes will be mined to a 3:1 ox less steep grade is correct, but that does not <br />apply in the initial mining area except on the south wall of that area which will be adjacent to the slurry wall. <br />This area would ultimately be reclaimed similar to Phase 1. <br />6. Item II F - This was very interesting. I am not sure what happened. Somehow the hatch patterns that were <br />actually printed are different from the ones that axe shown in the file I think we used in printing. But it is <br />possible I mistakenly printed an earlier uncorrected version. A new version of this map is provided. <br />7. Item III A - See response in 5 above. I think this clears up the confusion. <br />8. Item III B - As described on pages 17 and 18 of the reclamation plan, the alternative revegetation plan is <br />implemented in Phase 2 onlyif the reservoir is not implemented when the pit is completed and all the slopes are <br />finished. Keep in mind that Continental Materials will not be implementing the reservoir option. The plan is to <br />only create the vessel fox the reservoir with the view that another parry would use the site as a reservoir. Already <br />there has been interest expressed by others for a reservoir at this location, but most of these parties are not <br />interested in the site in an unsealed condition which would require them to install a slurry wall. The altematve <br />revegetation only applies to the situation where, at the end of the physical reclamation process, there is no other <br />party available to actually produce the reservoir (fill the vessel). In that case, the site would be revegetated with <br />the alternative plan and maintained in that condition until someone is ready to Fill the vessel with water and <br />thereby create the reservoir. This is virtually identical to the plan that was approved about 10 years ago fox the <br />portion of the Pueblo West Pit north of the Arkansas River. Also, please note that on page 4 of the reclamation <br />cost calculations (Exhibit L) the reclamation cost includes seeding the entire reservoir area under the assumption <br />that nobody will be available at the conclusion of the reclamation to actually fill the basin. That is not likely, but <br />that is the way the costs are determined because at this time the alternative revegetation plan is the only option <br />that is assured. <br />9. Item III A - As stated in 8 above, Continental Materials will not actually be creating the tilled reservoir. <br />However, there are sufficient water rights available to cover evaporative losses from groundwater seepage into <br />the sealed pit if the alternative revegetation plan needs to be implemented. <br />
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