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2010-07-19_REVISION - M1980146
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2010-07-19_REVISION - M1980146
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Last modified
6/15/2021 5:44:17 PM
Creation date
7/26/2010 8:27:11 AM
Metadata
Fields
Template:
DRMS Permit Index
Permit No
M1980146
IBM Index Class Name
REVISION
Doc Date
7/19/2010
Doc Name
Response to comment
From
Wasteline Inc.
To
DRMS
Type & Sequence
AM4
Email Name
RCO
Media Type
D
Archive
No
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WL-PM-E/Letter to: DRMS Subject: Response to Comments <br />• conditional approval by the Division pending continuing further confirmation of the <br />stability of the material (both exposed surfaces and backfilled slopes) as extraction <br />continues. <br />d. We will do everything possible to achieve a 3H:1 V or gentler slope on all portions of <br />the site, both in the areas addressed in item b and the newer western areas of the <br />permit. However, the major concerns are (1) the availability and suitability of material <br />for backfill, and (2) BLM requirements to mitigate visual impacts and protect trail areas <br />(as discussed in item a). <br />e. At present, based on the agreement between C&J and LaPlata County (and as <br />accepted by BLM) to daylight operations between the Montoya Pit and Crader Pit <br />(and assuming approval of an amendment or technical revision to the Crader Pit's <br />reclamation permit), we appear to have adequate materials to achieve the desired <br />3H:1 V slope on all portions of the perimeter (this was not the case when the EA and <br />amendment application were originally prepared). <br />f. In order to achieve 3H:1 V slopes in most of the area, based on material availability in <br />the future, it may be necessary to submit a revision to the reclamation plan to allow for <br />limited areas of slope with much steeper grades which would be stabilized by methods <br />other than revegetation. This may also be necessary in order to meet BLM conditions as <br />discussed in item a. As with the other areas discussed above, we understand it will be <br />necessary to closely monitor progress. <br />• 3. Exhibit F: <br />Again, these maps have been revised in the same manner as Exhibit C, for the same <br />purposes and for the purpose of showing desired post-reclamation slopes. As discussed <br />in Ref 1 (DRMS 27 Jan 10 letter), the assumption as to which areas will be revegetated is <br />correct, with the addition that BLM may require some areas NOT be revegetated or be <br />revegetated in specific ways in order to meet the requirements of the mitigation <br />measures listed in item 2.a. above. As also discussed in Ref 1 (DRMS 27 Jan 10 letter), the <br />topography shown in maps in Exhibit F is "conceptual" regardless of the scale of the <br />maps, either in hard copy or electronic form. See Maps F1, F2, and F3. Maps F4, F5, and <br />F6 are no longer required. <br />4. Right of Entry (Exhibit N) <br />This was discussed in Ref 3, where reference was made to BLM documents. A letter is <br />attached to this response, which states that C&J Gravel was authorized to mine in <br />Section 4; this will become an attachment to Exhibit N. The contract already provided <br />in Exhibit N identifies the right to mine in Sections 3 and 10. The maps show that mining <br />is no longer planned in Section 9. <br />• <br />PROJECT: Montoya Pit M-1980-146 AM-4 15 July 2010, Page 3
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