PERMFILE110154

• Permit No: M2004013
• IBM Index Class Name: Permit File
• Doc Date: 5/19/2004
• Doc Name: Response to Adequacy Review Letter
• From: Banks and Gesso LLC
• To: DMG
• Media Type: D
• Archive: No

Mr. Berhan Keffelew Page 3 of 4
May 18, 2004
break' has already occurred." Their letter report is attached.
E. The attached Martin and Wood letter addresses the Evans' wells (those closest
to the permit boundary), and finds that these wells should be able to continue to
pump effectively under normal conditions. In additional, all of the Evans' wells
are located at least 600 feet from the proposed pit boundary, so agreements are
not required by the State Engineer's Office. Finally, Mr. Evans is fully aware of
the proposed operation, through numerous personal meetings with Trans
Colorado Concrete and Banks and Gesso personnel, as well as County and
State notifications, and has not raised any concerns or objections to the project.
Trans Colorado Concrete has obtained a CDPS discharge permit from the
Colorado Department of Public Health and Environment (CDPHE), Permit No.
COG-500000, Facility No. COG-500453. Also, a Nationwide Permit No. 7
notification was submitted to the U.S. Army Corps of Engineers for construction
of the outtall structure, and was approved on April 30, 2004. Action #2004-00010
was assigned to this activity by the Corps.
G. A Substitute Water Supply Plan (SWSP) and Gravel Well Permit application for
this site was submitted to the Office of the State Engineer on April 14, 2004 and
is under review. The replacement water requirement contained in the SWSP
application for the first two year period (April 2004 through March 2006) is 24.63
acre-feet. This water requirement is being met through a lease with the Pueblo
Board of Water Works. The approved SWSP and Gravel Well Permit will be
obtained, and submitted to the Division, prior to exposure of groundwater. It is
our understanding that your Division can approve a Construction Materials
Reclamation Permit prior to receiving notification that these permits have been
approved, as long as the applicant commits to not exposing groundwater until
receiving both the SWSP and Gravel Well Permit. Trans Colorado Concrete
does commit to not exposing groundwater until receiving these permits and
submitting them to the Division.
VI. Exhibits H, I, J, and K -Adequate.
VII. Exhibit L:
A. Please see previous responses III-A and III-C.
B. The Division's bond calculation comes to approximately $14,285 per acre to
backfill above the water table. The applicant requests a partial bond for the first
25 acres of mining (about 5 years) or an amount of $357,125. After this time, the
applicant will submit a Technical Revision for the next phase of disturbance, and
a new financial warranty will be submitted to cover the subsequent phase of
disturbance. Also, within this initial timeframe, the Substitute Water Supply Plan
(SWSP) will have been approved and extended in two year increments to adjust
for changes in water loss as the mine advances.
VIII. Exhibits M, Nand O-Adequate.