2008-02-05_REVISION - M1981207 - Laserfiche WebLink

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Response to Adequacy Letter Technical Revision 6, M-1981-207 1 February 2008 Page 2 plant facility, it is noted that an angle of repose of at least 30 degrees is expected with the substrate on the site. The footprint of operations versus active side slopes supports settling to the angle of repose in the vicinity of the new concrete plant location; therefore, the plant will not be at risk of being buried in the event of a slope failure. By phone conversation, the Division also asked that the operator/permittee re-confirm reclamation to the post-mining land use of wildlife habitat and open space. There is no change proposed for the reclamation plan at this time, the affected area will be returned to the currently designated post-mining use of wildlife habitat in accordance with applicable standards. This Technical Revision, changing the location of a facility in place only during active mining, does not affect the Reclamation Plan. In the December 20 Inspection Report, the Division noted the financial warranty does not _ -.account-for-removal--of-the concrete- faciIity.. Pursuant to Rule 4.2.1 and its equivalent - statutory authority (e.g., C.R.S. § 34-32.5-117(4)), the DRMS may at any time review the financial warranty and determine that an adjustment in the bond is appropriate. The operator understands that this process may be instituted for the Blue Pit warranty, based on the Division's determination that backfill, demolition, and other costs have either increased or were not accounted for as dictated by current warranty calculation practices. The extent of concrete plant-related infrastructure and the cost of its removal is being examined, as requested by the Division, but is not part of the present Technical Revision request. Given the current reclamation plan for the site, as wildlife habitat, no amendment or revision is necessary to remove the concrete plant from the site. Therefore, the Division's request for a commitment to remove the concrete plant is needed only to clarify the implementation of the current reclamation plan for M-1981-207. As noted on the enclosed letter from Western Slope Aggregates, the intent to remove the concrete plant should now have "clear expectations for the purpose of documenting and bonding the M-1981-207 permit." It is our hope that this additional information and clarification will be adequate to complete the requested TR in a timely manner. Please contact me at 303-274-4277, or by electronic mail at aschatz(a?banksand esso.com, if any additional information is necessary. Sincerely, BAN S AND GESSO, LLC Ale chatz encl: Notarized Letter from Bill Roberts, President of Western Slope Aggregates cc: Carl Mount Colorado Division of Reclamation, Mining, and Safety 1313 Sherman St., Room 215 Denver, CO 80203