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STATE OF COLORADO <br />DIVISION OF RECLAMATION, MINING AND SAFETY <br />Department of Natural Resources <br />1313 Sherman St., Room 215 <br />Denver, Colorado 80203 <br />Phone: (303) 866-3567 <br />FAX: (303) 832-8106 <br />May 13, 2009 <br />g'W <br />MAY 10 2009 <br />COLORADO <br />DIVISION OF <br />RECLAMATION <br />MINING <br />SAFETY <br />Bill Ritter, Jr. <br />Governor <br />Division Ot Recl;;MatiGrA, Harris D. Sherman <br />Thomas Mathias Mir,lig, and Safety Executive Director <br />Mathias Concrete, Inc. Ronald W. Cattany <br />PO BOX 266 Division Director <br />Monte Vista, CO 81144 Natural Resource Trustee <br />., v v ? <br />Re: North Farm Road Gravel Pit, Permit M-1977-140, Technical Revision TR-3, Adequacy Review Letter. <br />Dear Mr. Mathias, <br />I have reviewed the requested change to the reclamation plan of the permitted operation named above, specifically to <br />eliminate the requirement for topsoiling and seeding the pond banks. By itself the technical revision request is concise <br />and straightforward. Further review of pertinent portions of the permit file raised a few questions that should be <br />clarified before this office may consider an approval decision. Given the requested revision to allow the future bank <br />surfaces to remain un-vegetated, it is important to determine past stability and to ensure future stability. Please address <br />the following underlined items. <br />Under the present reclamation plan the gradient of the banks is required to be 5:1. The proposed reclamation plan <br />revision does not seek to change this 5:1 gradient, which is consistent with Construction Materials Rule 3.1.5(7). You <br />have stated that the banks are all presently 5:1. Please confirm whether the 5:1 slopes extend at least five feet above <br />the static water line, and at least ten feet below the static water line in conformance with the rule cited above. If they <br />are not all 5:1 within that 15-foot elevation range, some grading may be required. <br />The existing pond banks are mainly covered by native cobble, with minor portions containing willow thickets near the <br />water line, as observed during past inspections. The cobble surface has exhibited little to no damage from wave action <br />or erosion from surface runoff. Have there been attempts to apply topsoil and/or seed the pond banks in the past? If <br />so, was the topsoil eroded, and/or did seeding efforts fail? How long have the banks existed at the present 5.1 <br />gradient? Has there been a need in the past to dress any of the slopes to remove damage? <br />The area affected under this permit has yielded varying amounts of topsoil, and little has been salvaged for reclaiming <br />the pond slopes. Please note that reclamation of the level portions of the permitted area will still require topsoil and <br />seeding as part of the reclamation plan. Given the scarcity of this resource that is required for reclamation please <br />confirm that efforts will continue to be made to carefully segregate and stockpile available topsoil and growth media <br />for future reclamation of the level facilities and processing area. <br />Though this revision request seeks to remove the requirement for seeding the slopes, this office encourages the <br />continued presence of the willow thickets, where they naturally spread and become established. There is no <br />requirement for planting the willows, though they can enhance and help stabilize the pond margins. However, as with <br />all affected areas in the permit, whether vegetated or not, reclaimed or not, noxious weeds must continue to be <br />regularly monitored and treated timely. Please confirm that weed control will continue to be carried out. <br /> <br />Office of Office of <br />Mined Land Reclamation Denver • Grand Junction • Durango Active and Inactive Mines