2008-02-15_REVISION - M1981207

• Permit No: M1981207
• IBM Index Class Name: Revision
• Doc Date: 2/15/2008
• Doc Name: Adequacy comments
• From: Banks and Gesso, LLC
• To: DRMS
• Type & Sequence: TR6
• Email Name: THM
• Media Type: D
• Archive: No

No Banks and Gesso, LLC ?N
No
11 February 2008
R C M D
FEB 15 2008
GRAND ,IUNUIQN HELD OFFICE
DIVISION OF
RECLAMATION MMING & SAFETY
Travis Marshall
Colorado Division of Reclamation, Mining, and Safety
101 South 3rd St., Suite 301
Grand Junction, CO 81501
Re: Response to DRIVIS Adequacy Comments of February 6, 2008,
Blue Pit, M-1981-207, TR-06
Dear Mf!M rshall:
RECEIVED
FEB 2 5 2008
Division of Reclamation, f-I
Mining and Safety
This letter is a response to the technical and procedural issues raised by the Division of
Reclamation, Mining, and Safety letter of February 6, 2008, concerning the Blue Pit (M-
1981-207). This letter is submitted in anticipation of a February 22, 2008 decision date.
It is the operator's intent to resolve all issues newly identified in the referenced letter
from the Division. As you noted in our conversation on February 8, the Division has no
outstanding issues related to the operator's certification that the concrete plant will be
removed, or any other aspect of the Technical Revision (TR-06) request already
reviewed and commented on prior to the February 6 letter. It is assumed for the
purposes of this response that the outstanding review issues for TR-06 are limited to the
Division's February 6 letter and any future actions related to this review.
The operator's request in the present TR is to relocate an existing facility, as required to
fulfill the intent of the currently operative, approved mining plan and reclamation plan for
the site. The current permit holds that plant facilities located, at present, in the center of
the site will be moved over the course of mining to allow for recovery of sand and gravel
deposits underneath the center of the site. Moreover, the current permit anticipates
relocating the plant to an already-mined area, where plant operations will continue until
reclamation. Finally, at the time of reclamation, according to the current permit, the plant
will be removed and is not a part of the post-mining use. In all these respects, the
current permit allows the operator's request.
As outlined in the operator's November 30, 2007 TR request, the only change sought is
the location of the plant in the southwestern corner of the affected area instead of the
northeastern corner, which allows the operator to adjust the sequence of mining to a
continuous westward excavation instead of the three-phased sequence originally
envisioned (see discussion below). Given prior approval of plant relocation as a
technique to be used in the Blue Pit, the requested change is a minor deviation from
approved plans.
720 Kipling St., Suite 117
Lakewood, Colorado 80215
[phone]
Fax [phone]
www.banksandgesso.com
We agree that clarifications related to the Division's two comments from its February 6
letter are important. In the response below, we discuss application of the Division's
technical concerns to the TR-06 request. As I have advised in our recent phone