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~/ <br />®® Banks and Gesso, LLC 720 Kipling St.,Suite117 <br />^. Lakewood, Colorado 80215 <br />November 18, 2004 <br />(303)274-4277 <br />Fax (303) 274-8329 <br />www. banksandgesso.com <br />RECEIVED <br />Erica Crosby <br />Division of Minerals and Geology NOV i 9 ZOD4 <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 8irision ~f Miaerels and Geolo9Y <br />Subject: CEMEX, Inc., Lyons Quarry, Permit No. M-1977-208 <br />l~R-03; Response to Adequacy Letter <br />Dear Ms. Crosby <br />On behalf of Cemex, Inc., we offer the following response to the Division's Adequacy <br />Letter dated November 10, 2004. <br />A-Pit Fencing -The Division is correct that there is currently not a fence along <br />the A-Pit highwall. Cemex has addressed safety concerns regarding public <br />access to A-Pit by installing a fence around the perimeter of the Cemex-owned <br />property (combination of chain-link and barbed wire, with locking gates at vehicle <br />access points) and maintaining "No Trespassing" signs at approximately 100 foot <br />intervals along the site perimeter. <br />2. Highwall Stability - It is the opinion of Cemex that they are in compliance with <br />Rule 3.1.5(3) requiring that all highwalls be eliminated or stabilized. The existing <br />highwalls have proven themselves stable for many years. Cemex and its <br />predecessor companies have not noted ~ significant slope stability problems in <br />the history of mining at this site (~35 years). <br />As discussed in our original Technical Revision request letter, dated October 21, <br />2004, reclamation is complete at A-Pit reservoir and at the small pond that we <br />will refer to as "Leiding Pond" (located in the southwest portion of C-Pit, as <br />labeled on the attached map). The total remaining highwall in both areas is <br />approximately 1,400 linear feet, less than half of the Division's approved length <br />(5,000 feet) in the 1984 Technical Revision approval. <br />In addition, please note that highwalls account for less than half the total pond <br />perimeter in both cases, and the site is not easily accessible by the public. <br />Cemex has no plans to convert the site to public use. Safety issues are <br />addressed via fencing and prohibitions on public access, and stability issues are <br />not relevant to the current or future use of the site. Even if portions of the <br />highwalls were to become unstable or collapse at some future time, there would <br />be no remediation necessary by either Cemex or the State, as collapse would not <br />