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~ III IIIIIIIIIIIIIIII <br />IRELAND, STAPLETON. PRYOR 6 PASCOE, P. C. <br />ATTORNEYS AT LAW <br />SUITE 2600 <br />OWEN C. ROUSE $ <br />165 BROADWAY <br />POST OFFICE BO% ~a10 <br />DENVER,COLO RADO 80201 <br />May 9, 1985 <br />Mined Land Reclamation Board <br />423 Centennial Building <br />1313 Sherman Street <br />Denver, Colorado 80203 <br />Re: Permit No. 74-41, Lawrence Const <br />Dear Sirs: <br />TELEPHONE 303 623-2]00 <br />TELECO PIER 303 623-2062 <br />I ,, . <br />` - ~ ~ ~,.: <br />r ,,, <br />tion <br />Lawrence Construction Company respectfully requests that <br />the Mined Land Reclamation Board take such action as is necessary <br />to restrain and prevent mining operations which are presently <br />underway on the property, to the extent that those operations <br />violate the permit. At the present time, Brinkmann-Woodward <br />Construction Company is conducting operations on the property. <br />Brinkmann-Woodward is operating in violation of the <br />permit and in spite of the objections and protests of Lawrence <br />Construction Company. Since October of 1984, Lawrence Construc- <br />tion Company has repeatedly notified Brinkmann-Woodward Construc- <br />tion Company that the pit is being operated in an unacceptable <br />manner, and has demanded that operations cease and that <br />Brinkmann-Woodward vacate the premises. However, Brinkmann- <br />Woodward has refused to vacate the premises and has made no per- <br />ceptible effort to change the manner of operation. Brinkmann- <br />Woodward is doing the following things which we believe violate <br />the terms and conditions of the permit: (1) deviating from the <br />mining plan by expanding the operation to more than ten acres <br />without conducting any reclamation; (2) extracting two or three <br />times the allowable tonnage of sand and gravel; (3) excavating set- <br />tling ponds below the elevation specified in the permit; (4) op- <br />erating without an air quality control permit; (5) using water from <br />Plum Creek to wash materials without either a water quality con- <br />trol permit or any title or claim to the water; (6) permitting open <br />drainage of waste water across the surface of the pit and access <br />roads; and (7) interfering with the storage and retention of topsoil <br />to be used in connection with the eventual reclamation of the <br />pit. <br />