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• Green/Croissant Sand and Gravel M~esponse to Adequacy Review <br />May 30, 2001 <br />Page 10 <br />6.4.19 EXHIBIT S -Permanent Man-Made Structures <br />21. In accordance with Rule 6.4.19, the Applicant has submitted five Structure <br />Agreements with this letter (see Item 1 above). Our understanding is that the <br />submission of these Agreements to the DMG is a routine administrative <br />process and does not constitute a revision or amendment to the permit every <br />time an agreement is reached. As referenced in Item 13, the mining limits <br />contained in the 112 application represent a scenario of greatest impact and <br />account for the condition of maximum disturbance. <br />If the submission of Structure Agreements at this time, or at any time in the <br />future, will trigger a Technical Revision or Amendment process, we request <br />an explanation of Section 115(4)(e) of the Reclamation Act. The DMG has <br />stated in the past that Structure Agreements are its preferred method of <br />satisfying Section 115(4)(e), yet the policy introduced in Item 21 of the <br />Green/Croissant Adequacy Letter does not seem to allow for the normal <br />process of negotiation typically involved with obtaining Structure Agreements. <br />Structure Agreements (or proof of abandonment in the case of the Machi- <br />Ross structure) for the pipelines specifically mentioned in Item 21 are still in <br />the negotiation process. Should engineering analysis be contemplated for <br />these structures, the analysis will include a statement regarding the necessity <br />of armoring and/or pressure equalization. However, until such time that <br />either an Agreement is reached or engineering analyses have been <br />successfully produced, the Applicant reemphasizes its commitment to avoid <br />mining operations within 200' of permanent man-made structures. <br />22. Exhibit S has been modified to reflect the complete ownership list for <br />structures on the Green/Croissant property (see below and attachment). <br />With regard to the specific structures noted in the DMG Adequacy Letter: <br />(a) The gas appurtenance in the northwest corner of the site <br />is part of the Public Service pipeline system. The <br />Structure Agreement sent to Public Service was amended <br />to reflect this. <br />(b) Machi-Ross abandoned the "Klien" well and related <br />gathering lines on the Green property this May. Exhibit S <br />has been revised to clarify Machi-Ross' ownership; <br />however, the abandonment of this well and pipeline may <br />give Loveland Ready Mix control over the abandoned <br />structure. <br />(c) Loveland Ready Mix owns the tailwater ditches on the <br />site. Exhibit 'S' has been appropriately revised, but no <br />Structure Agreement will be necessary since the <br />Applicant is the structure owner. <br />