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' 0[ Banks and Gesso, LLC <br />?Cl <br />February 1, 2008 <br />720 Kipling St., Suite 117 <br />Lakewood, Colorado 80215 <br />(303) 274-4277 <br />Fax (303) 274-8329 <br />www.banksandgesso.com <br />RECEIVED <br />Travis Marshall FEB 0 5 2008 <br />Division of Reclamation, Mining, and Safety Division of Reclamation, <br />Grand Junction Field Office Mining and Safety <br />101 South 3`d Street, Room 301 <br />Grand Junction, CO 81501 ?? / <br />Re: Blue Pit, M-1981-207, Technical Response to DRMS Comments Concerning <br />Proposed Technical Revision 6 <br />Mr. Marshall: <br />This letter is in response to the Inspection Report, dated 12/20/2007, concerning the <br />Blue Pit (DRMS M-1981-207), as well as the Division's January 11, 2008 adequacy <br />letter. The referenced inspection was prompted by a November 30, 2007, Technical <br />Revision submitted on behalf of Western Slope Aggregates by this office. The requested <br />Technical Revision consists of the relocation of an existing concrete plant facility. <br />The objective of this Technical Revision is solely to seek the Division's concurrence <br />regarding the new location for the on-site concrete plant. Given the operator/permittee's <br />submittal of the statement that the plant will be removed at the close of mining, this TR <br />process should no longer require certain technical documentation identified in the <br />Division's recent correspondence. Specifically, we have discussed and agreed by <br />phone to simplify and limit the current process to only approval of the new location of the <br />concrete plant. As a result, items 2 through 5 of the Division's January 11 letter no <br />longer apply to the TR request. <br />Item 1 in the Division's January 11 letter reiterates the comment provided in the <br />Division's December 20 Inspection Report. The concern expressed is based on post- <br />mining use and reclamation that would continue concrete plant operations. The <br />withdrawal of this proposal is accomplished by this letter and the enclosed letter <br />submitted by Bill Roberts certifying that the concrete plant will be removed prior to <br />release of Reclamation Permit M-1981-207. The notarized statement committing to <br />remove the plant is submitted in lieu of reclamation plans to include the concrete plant <br />and detail the plant in a post-mining layout with associated engineering. <br />By phone conversation, the Division requested assurance that the concrete plant would <br />not be placed at risk during the mining operation: Since the relevant time period is prior <br />to final reclamation, the standard to be applied is not specified by prior action. or any <br />specific Construction Materials Reclamation Rule. _ Rather, conveyors, scrapers, and <br />other equipment, including plant facilities, are frequently mobilized in pit floor areas. <br />Risks to capital equipment are not regulated (e.g., there is, for example, no DRMS <br />insurance requirement for operator equipment) and federal regulations enforced by <br />MSHA account for the basic safety of the site and equipment. Nonetheless, assuming <br />there is a regulatory basis for the DRMS to ensure that slopes will not encroach on the