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shrubs as EFCI has committed to <br />reclamation cost, increasing <br />$111.00/acre. For the refuse area, <br />is needed, and a $4.44/acre cost a <br />10. Failure for revegetation rate <br />25$. Please adjust accordingly. <br />in the permit, into the <br />the facility area by <br />an increase of $35.52/acre <br />t the loadout is required. <br />in the Canon City area is <br />Items 48 and 49: Thank you for your response, however since the <br />permit organization seems difficult to comprehend, the Division <br />would like to suggest that on the next complete inspection, that <br />this item be discussed and explained further as to referencing <br />options and organization as implied in your response. <br />Item 50: Replacement of topsoil depths to anything less than the <br />required four foot minimum as stated in Rule 4.10.4(5) is dependent <br />upon submittal of proof that vegetation can grow on less for the <br />area, only after the operation has tested the less than four foot <br />cover in a scientific manner, the results being field tested, as <br />proposed in your letter to the Division during the PROs process, <br />and responded to by the Division as a denial, but that they(the <br />Division), "will consider a variance based on the results of field <br />tests which the operator has proposed." (Letter enclosed). Also <br />refer to the "Proposed Decision and Findings Document" 1991, page <br />17, X.Topsoil, 2nd paragraph, 2nd sentence: "Topsoil depths will <br />remain as previously approved, 4 feet, unless test nits in the pile <br />e~ansion area indicate that a lesser death of salvageable material <br />is available." To date, the Division is not aware of any such <br />test plots or pit experiments being conducted on the site. If such <br />plots exist, then upon next inspection, please indicate their <br />location and progress. Until such time as field tested results are <br />submitted and approved as a technical revision, please remove <br />mention of less than four feet of cover from the revised pages <br />submitted or any in the permit. In other words, at minimum, the <br />following pages must be revised: <br />1. 2.05.4-14R, 4th paragraph, "placement of approximately <br />four (4) feet of soil material; <br />2. 2.05.4-15R, strike all references to refuse and soil <br />materials being similar (2nd P, 1st sentence), as this has not <br />been proven or approved as a technical revision; <br />3. same page, 3rd P: delete all references to a "reduction of <br />soil replacement..."(2nd and 3rd sentences). <br />4. Same page, 3rd P: 4th sentence, delete "continue" and end <br />sentence at "stockpile areas." <br />5. 2.05.3-36Ra: end 1st sentence at "cover depths", deleting, <br />"the soil replacement plans will be modified accordingly." <br />Modification is determined upon submittal and approval of a <br />revision to the original plan, and none have been submitted to <br />date. <br />6. 2.05.3-58R: 2nd P, eliminate last sentence. <br />7. same page: 3rd P, this was in verbal agreement only to an <br />EFCI suggestion during permit revision in 1991. To date, the <br />Division has seen no revision submitted to indicate that the <br />intention by EFCI is to develop test plots, therefore, this <br />paragraph must be deleted. <br />