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Venture Resources, Inc. <br />PO Box 1974 (303) 619-6323 <br />Idaho Springs, CO 80432 Fax: (303) 484-6369 <br />ventureresources C -att.net <br />November 18, 2010 <br />CO Division of Reclamation, Mining & Safety <br />1313 Sherman St., Room 215 <br />Denver, CO 80203 <br />Attn: Jared Ebert <br /> <br />RE: M-2009-076 Application <br />Subject: Response to remaining items within DBMS' Sept. 8`h Second Adequacy Review <br />Dear Mr. Ebert: <br />Venture Resources submitted a Technical Revision dated November 10, 2010 which was a response to the stability <br />concerns outlined in the DRMS' September 8"' Second Adequacy Review. We are also in receipt of your November <br />16`h letter requesting a response to the remaining items of that same Review so that a DRMS decision can be made <br />prior to the November 24`h anniversary date of our permit application. <br />Below is our response to the remaining items, which we feel do not constitute a technical revision, but rather simple <br />clarifications and slight changes to our design. The responses are enumerated in the same manner as the September <br />8`h Second Adequacy Review: , <br />Page 1, Item #1: Venture Resources (VR) submitted a Technical Revision addressing this, dated November 10`h. <br />Page 1, Item #2: VR submitted a Technical Revision addressing this, dated November Ioh <br />Page 1, Item #3: VR submitted a Technical Revision addressing this, dated November 10`h <br />Page 2, Item #1: The buttressing fill below the concrete barrier wall was constructed in the same manner as the <br />sediment pond embankment (see below). This fill is not a structural requirement, as the concrete barrier is designed <br />with a cantilevered footing to stand alone with impounded tailings on the "wet" (north) side. This fill acts as an <br />extreme, second degree of over-design to support the concrete barrier. The design is adequate and construction of <br />the concrete barrier was supervised by a Professional Engineer. <br />During a meeting with the DRMS on November 8'h it was determined that the reclaimability of 1.5H:1 V slopes will <br />not pose a problem with this relatively small project. This was again addressed in our November 10"' Technical <br />Revision. Our reading of Rule 3.1.5(9) and 6.3.4(l)(b) does not preclude slopes steeper than 2:1 for the reclamation <br />of a pond or 3:1 for other reclamation. No pond is proposed for final site reclamation. No excavated slopes are <br />proposed other than for construction of the tailing dam. These areas will have tailings deposited. <br />In regard to the sediment pond embankment Exhibit E 13 states: "Fill material shall be placed in 8- to 12-inch lifts <br />over the entire width of the embankment. Compaction shall be obtained by routing the excavating equipment over <br />the fill so that the entire surface of each lift is traversed at least once by the equipment tire/track. " This compaction <br />specification is absolutely sufficient, especially considering the fill material consists primarily of rock and cobble. <br />This structure is less than 6' tall and is well over 12' wide, spanning a short distance of less than 100'. It is <br />designed to be a sediment trap during large storm events. The design is adequate and construction of both the <br />concrete barrier and sediment pond was supervised by a Professional Engineer. Remember, this structure was built <br />prior to DRMS involvement during a period which was under a perceived CDPHE jurisdiction. Additionally, this <br />Page 1 of 4