2006-05-30_REPORT - M1998003 - Laserfiche WebLink

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2 Raftopoulos Pit The Raftopoulos Pit No. 1 is a good example of Moffat County's operation. The facility was permitted in 1998, and the crusher crew produced and stockpiled a measured 30,000 yazds of road-base in Mazch of 1999. You and I made a routine monitoring inspection on July 13, 1999, of the "new disturbance" and of the general field conditions of the mine. Nearly five years later, on April 13, 2004, Gregg Squire and I made a routine monitoring inspection of the same pit and there was no new disturbance during that past five years. Moffat County operates all of the gravel pits in the same general pattern: (1). Within two years after a new MLRB permit or a conversion has been issued, _ the county construction.crew_will strip_the_topsoil, and the_overburden,.and,place these materials into their respective stockpiles; (2). The crusher crew will mine and stockpile 30,000 cubic yards of crushed road- base materials; (3) I prepare a map of the "new disturbances" and, on the first anniversary date, we attach it to the signed Annual Report request form -and file it; (4) Typically, it takes from five to ten years of "stockpile reduction only" activity to deplete the crushed gravel stockpile, therefore, when there are "no new disturbances", or "new reclamation", we make a statement on the Annual Report Request form to that affect -under the provisions of Rule i .15 (2), and Gregg Squire's recommendation described below. Auuual Reports Gregg Squire knew our gravel operation for what it was. He suggested that the formal written "Report" was not useful, and he directed me to make a map of the "new disturbances" or the "new reclamation" only when they occurred, and to add a brief note on the Annual Report Request page. In the cases where there had not been any changes (which was in most circumstances), Gregg recommended that I make a note such as _"Stockpile-Reduction Only = No Mbp 1Ve"eessary" or"`Reclbmdti5n Only = No Map Necessary" on the Report Request form. I have filed, and the Division of Minerals and Geology has accepted, an estimated 150 annual reports on Moffat County's gravel pits in that format over the last 10 years. In the past few weeks, Michelle Ramirez has rejected Moffat County's annual reports declaring them "inadequate". The enclosed letter copy dated 05/01/06 from Ms. Ramirez is confusing where she refers to the Annual Report inclusions for the Raftopoulos Pit. There aze two sentences in pazagraph 2 that contradict each other: (Ms. Ramirez's Sentence #2) "...Please submit either a written report or an adequately labeled map, as required by Rule 1.15." (Emphasis added).