2004-01-21_REVISION - M1983176

• Permit No: M1983176
• IBM Index Class Name: Revision
• Doc Date: 1/21/2004
• Doc Name: Comments on Adequacy Review of 01/12/04
• From: Asphalt Specialties Co Inc
• To: DMG
• Type & Sequence: AM3
• Media Type: D
• Archive: No

RECEIVED
ASPHALT
SPECIALTIES CO.
7321 East 88th Ave. Henderson, CO 80640
JAN 21 2004
Division at Mineral:: da 34"'~9Y
• [phone] Fax: [phone]
January 17, 2004
Mr. Berhan Keffelew
Colorado Div. of Minerals and Geology
1313 Sherman Street, Room 215
Denver, Colorado 80203
RE: Comments on your Adequacy Review of January 12, 2004 for Amendment No. 3,
Sneer Mining Resource Permit No. M-1983-176
Dear Berhan:
In order to complete the referenced amendment process through the Division of Minerals
and Geology for our Speer Mining Resource site, I am responding to your adequacy
review with this letter. I will comment on your statements with regard to the individual
DMG "Exhibits" in the order presented in your referenced letter:
1. Urban Drainage and Flood Control (not contained in your referenced letter, but
sent to me via fax on 1-12-04. This same letter was sent to Adams County, as the
issues really concern only the County):
• The Floodplain Use Permit (FUP) is a document that is a permitted use
given by Adams County and not the State of Colorado. This permit is still
in the development stage as there have been many technical issues to
overcome. The mining will progress on the AM-3 area prior to the final
issuance of the FUP, as the amendment area is far from the South Platte
River, but the FUP will be obtained in a timely manner this year.
• The backfilled lower bench (Area 2) was only completely backfilled this
past Fall. No final grading, final topsoiling or seeding has taken place.
This will be accomplished this Spring (2004) as shown on the submitted
annual report for this site. The area has only a slight grade towards the
river and no erosion is occurring or will occur. As stated in the second
amendment for this permit, there was a mistake in the original amendment
to this permit (AM-1) that showed the lower bench area to contain
"wetland plants" as part of final reclamation on the reclamation plan map
(Exhibit F). However, the bench was to be backfilled to the grade
previous to mining. There never was any wetland vegetation on this point
bar, and backfilling to grade would not allow wetland plants to establish,
as the grade will be 5-6 ft. above the water table. The reclamation text
(Exhibit E) in the first amendment to this permit (February 2000) never