2011-06-09_PERMIT FILE - M2011001

• Permit No: M2011001
• IBM Index Class Name: PERMIT FILE
• Doc Date: 6/9/2011
• Doc Name: Response to 2nd Adequacy Review Comment #31 and Proof of Filing with Weld County
• From: Tetra Tech
• To: DRMS
• Email Name: PSH
• Media Type: D
• Archive: No

TETRA TECH
RECEIVED
JUN U e ZoI!
June 8, 2011
Mr. Peter S. Hays
Environmental Protection Specialist
Division of Reclamation, Mining and Safety
1313 Sherman Street, Room 215
Denver, CO 80203
Dlvislon of Reclametlon,
Mining & Safety
RE: Response to Iverson Mine (M-2011-001) Second Adequacy Review Comment #31
Dear Mr. Hays:
Below is the Iverson Mine Second Adequacy Review Comment #31 followed by Lafarge's response to the
comment.
31. The Division will estimate the cost to reclaim the site based on the information submitted once the
Applicant addresses the concerns noted in this letter.
In addition, the Division will include costs to comply with the Office of the State Engineers
requirement for out-of-priority groundwater depletions. The reclamation plan proposes 44.1 acres of
open ground water will remain after the site is reclaimed. Lafarge or the landowner must obtain a
court approved augmentation plan from the Office of the State Engineer. The Division is required to
set the financial warranty at a level which reflects the actual current cost of fulfilling the conditions of
the Reclamation Plan per Rule 4.2.1(1). Therefore, without an augmentation plan in place the
financial warranty must be set at an amount which accounts for the exposed groundwater. The
Division has identified several options for determining the amount of the financial warranty. The
Applicant must choose one of the following options to be included in the financial warranty
calculation:
a. Backfill all of the pits to two feet above the groundwater level.
b. Install a slurry wall or clay liner.
c. Provide the Division with documentation from SEO, which demonstrates the Applicant owns a
sufficient amount of shares of water to cover the evaporative losses from the exposed
groundwater and the said shares have been committed to the SEO should the financial warranty
forfeited and the permit revoked.
If the Applicant obtains an augmentation plan prior to final release, then the financial warranty will be
adjusted accordingly.
Comment from Second Adequacy Review letter:
The Division prepared a preliminary reclamation cost estimate for the Iverson Pit. The Division
estimates the total cost to reclaim the site is $233,400. The estimate is based on the Applicant
choosing Option C above and will require recalculation if a different option is chosen by the Applicant.
A copy of the estimate is enclosed for your review.
Lafarge has chosen to go with Option C. Attached please find a letter from the SEO to fulfill the
documentation requirement.
1900 S. Sunset Street, Suite I-F, Longmont, CO 80501
Tel [phone] Fax [phone] www.tetratech.com