2002-11-25_REVISION - M1977344 (2)

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8. In accordance with Rule 6 Section 4.4(e), you have provided a timetable for the mining operation. However, this section also requires that the timetable establish the relationship between mining and reclamation. Please provide a detailed description, including timeframes, of how reclamation will follow mining. In particular the Division wants Holcim to comtni[ [o completing final reclamation, topsoiling and revegetation, in a timely manner. How soon will final reclamation occur after a mine cut has been backfilled? 9. Rule 6 Section 6.4.4(e)(i)-(iii) requires information regazding a proposed timetable to describe [he mining operation. It appeazs that much of that information would be in table D-1, which your application says will be provided under sepazate cover as confidential information. We have not received table D-1. Please provide that table. 10. There is a small block of land adjacent [o and west of mining cut 2 on your mining plan map, which is no[ numbered but is delineated in the same manner as the numbered cuts. Will [ha[ azea be mined? Please make the necessary corrections to your map to clarify this matter. 11. The construction materials rules a[ 6.4.4(f)(i and ii) require information on the nature, depth and thickness of the deposit to be mined and the thickness and type of overburden to be removed. This information may be mazked CONFIDENTIAL. These sections also require information on the nature of the stratum immediately beneath the material to be mined. Please provide that information. 12. Provide your plan to prevent damage (due to blasting) to the natural gas pipeline running through extraction cuts 13, 14, 16 and 18. Exhibit E -Reclamation Plan 13. Rule 6 Section 4.5(2)(c) requires a description of how the reclamation plan will be implemented to meet each applicable requirement of Rule 3 Section 1. Your application states that "All applicable requirements of section 3.1 of the rules aze addressed elsewhere in this application. The applicable requirements must be addressed in Exhibit E. 14. Rule 3 Section 1.5(1) states that grading shall be carried on so as to create final topography appropriate to the final land use. Your application's mining plan states that the pit will be backfilled by dumping overburden from trucks leaving a slope a[ the edge of the backfilt of approximately 1.3h:1 v. That slope is not appropriate to the final land use of rangeland. I[ is too steep to be traversed by livestock (see Rule 3.1.10(3)). The 1.3:1 slope is too steep [o successfully re-vegetate and prevent excessive erosion and siltation. The presently approved reclamation slope for this permit is 3:1. It is Division policy not to approve, in a modification to a permit, reclamation measures that aze not as adequate as [hose approved for [he original permit. If Holcim wants to propose steeper slopes, your proposed reclamation plan must demonstrate to the Division that Holcim will be able to permanently stabilize and re-vegetate the slopes successfully to rangeland. 15. How soon after a mine cut is backfilled will topsoiling and re-vegetation occur? 16. Lt order [o comply with Rule 3 Section 1.6(b), state how Holcim will protect the water quality of lower Beaz Creek. The Division is primarily concerned about siltation of [hat portion of the Creek and the Arkansas River. Provide your plan to prevent siltation of these streams. Holcim should consider a system of sediment control structures, for those cuts [hat have the potential to add sediment to the drainage system. Another option would be a lazge sediment control facility (dam/pond) in or neaz cut 4 where the creek leaves the affected land area. If you elect this opton, provide detailed construction plans for the facility and discuss whether it will be a permanent facility. Colorado water law requires the release of surface runoff within 72 hours unless a water storage right is obtained. Keep in mind that, if such a facility is proposed and it will requre dredge or fill in waters of the United States or destroy wetlands in azeas not covered by your present 404 permit, additional permitting may be necessary. L you propose sediment control facilities that would be constructed throughout