1995-02-28_REVISION - M1977315

• Permit No: M1977315
• IBM Index Class Name: Revision
• Doc Date: 2/28/1995
• Doc Name: BESTWAY PAVING CO PIT 1 AMENDMENT 1 ADEQUACY REVIEW FN M-77-315
• From: DMG
• To: TUTTLE APPLEGATE INC
• Type & Sequence: AM1
• Media Type: D
• Archive: No

• , iii iiiiiiiiiii
STATE OF COLOMDO
DIVISION OF MINERALS AND GEOLOGY
Department of Natural Resources
1313 Sherman St., Room 215
Denver,Colorado 80203
Phone:[phone]
FAX:[phone]
DEPARTMENT OF
February 28, 1995 NATURAL
RESOURCES
Mr. Gary J. Tuttle and Mr. John Jordan Roy Romer
Tuttle Applegate, Inc. cover"°'
ead
11990 Grant Street Suite 410 Eames iyeS. Di, cro,
E.ecutive Director
Denver, CO 80233 Michael B.Long
Drvmon Director
RE: Bestway Paving Company, Pit No. 1 - Amendment No. 1 - Adequacy Review -
File No. M-77-315
Dear Messers Tuttle and Jordan:
The Division has completed its adequacy review of the Bestway Amendment and has the
following comments:
1. The amendment includes the removal of 17 permitted acres. The definition of
an amendment, Rules and Regulations, Section 1.1(6), includes ". . . a change
in the permit which increase the acreage of the affected land. . . ". This
defmition does not include the removal or release of permitted areas.
To release the 17 acres the operator must follow the requirements of
Section 4.16 of the Rules and Regulations. There is no fee required for this
action.
2. Exhibit L - Reclamation Costs - The application states that the costs are
unchanged from the original application. The current reclamation bond is
$24,000.00; based on a "floating bond" which assumed that as one of the 15
phased areas was mined out reclamation would begin with no phased area
going more than five years between initiation of reclamation procedures and
completion of reclamation (See Part D - Reclamation Plan of the original
permit application).
It appears from the current amendment application that this phased reclamation
plan was not totally followed. This also appears to be the case based on the
operator's annual reports. In addition, reclamation costs have increased since
the bond was estimated in 1978, and, with the proposed reduction in size of
the pond from 14.1 acres to 6.0 acres, grading, topsoiling, and seeding costs
will increase. Therefore, the Division is requesting that the operator submit
the information necessary to calculate the costs of reclamation as described in
Section 6.4.12 - Exhibit L of the Rules and Regulations.