REV105253

• Permit No: M1989029
• IBM Index Class Name: Revision
• Doc Date: 11/29/2000
• Doc Name: LONGMONT DISTEL OPERATIONS-AM-3-ADEQUACY LETTER PN M-89-029
• From: DMG
• To: CAMAS COLO INC
• Type & Sequence: AM3
• Media Type: D
• Archive: No

6,4.10 EXHIBIT .1 -Vegetation Information
3. Exhibit I does not contain a weed control plan for noxious weeds present within the proposed affected
land. During the Division's August 2, 2000 inspection, this reviewer noted a number of noxious weeds
present (tamarix, purple loosestrife, diffuse knapweed, and Canada or musk thistle). In order that the
applicant will be able to demonstrate compliance with Rule 3.1.10(6), the Division requests that the
applicant provide a weed control plan for all noxious weed species present within the proposed affected
land. If additional time is needed to prepare such a plan, the applicant may commit to providing such a
plan prior to disturbance in the Amendment 3 azea. (Such a weed control plan, if not available by
Decemb~,r 20, 2000, may be incorporated into the mining & reclamation plan via a technical revision). For
assistance in preparing a weed control plan, we suggest you contact the Weld County weed control
specialist Mr. Ron Brody at [phone]. Other sources you may wish to contact include Eric Lane of
the Colorado Dept. of Agriculture at [phone] or K. George Beck of Colorado State University at
[phone].
6.4.12 E'.KHIBIT L -Reclamation Costs
4. There appears to be a discrepancy in the reclamation costs regarding the total volume of topsoil and
overburden to be regraded (1,191,713 cubic yards) vs. the total volume listed in Table 6.1 (1,857,100).
Please explain where the difference of 665,387 cubic yards comes from and which total volume is the
correct volume to use in the reclamation cost estimate.
5. The indirect cost applied by the Division in reference to Rule 6.4.12 includes 18.5%o and 5% for a total
of 23.5%, rather than the l0% used in the applicant's estimate on Table 13.1. Attached is a copy of the
Division's estimate, assuming a total indirect cost of $1,483,753.
6.4.13 E?:HIItIT M -Other Permits & Licenses
6. The api~licant states that the proposed mining of the Longmont property will include excavation of
jurisdictional wetlands. The applicant proposes in the reclamation plan that six (6) wetland areas for a
total of 34 acres will be created. The applicant also proposes that the final outfall from the Longmont pond
to St. Vrain Creek will require the placement of a limited amount of fill into St. Vrain Creek. In
conformance with Rule 6.4.13, please indicate the status of any and all permits required by the U.S. Army
Corps of ingineers for such activities. Any such permits required by the Corps should be incorporated
into the mining & reclamation plan as they become available. (Attached are comments from the Corps of
Engineers).
7. The applicant specifies in the mine plan that dewatering will be required to facilitate mining operations.
Also, the applicant has identified in Exhibit C.4 the locations of registered wells on or near the proposed
affected land. Review of Exhibit C.4 indicates that there are six (6) wells that will be within 600 feet of
the proposed disturbance (Peschel-2 wells, Distel-1 well, Longmont-3 wells). Further, the applicant states'
that reclamation will include creation of 4 ponds for a total of 75 acres. This will entail exposure of
alluvial gn~undwater and is likely to require a temporary substitute supply plan during mining and a
permanent augmentation plan during final reclamation. In conformance with Rule 6.4.13, please indicate
the status of any and all permits required by the Office of the State Engineer (OSE) prior to exposure or
dismrbance of groundwater via dewatering. (Attached are comments from the OSE).