2012-04-10_HYDROLOGY - M1991035 (2)

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T l., Applegate Group, inc. Water Resource Advisors for the West April 9, 2012 Mr. Tony Waldron Division of Reclamation, Mining and Safety 1313 Sherman Street, Room 215 Denver, CO 80203 Re: Response to _DRMS Letter Regarding M1991035 (Bluestone Pit); M19.2404�J Dear Tony: Vk I 1qj10) RECEIVED APR 10 2012 Division of Reclamation, 7 v Mining & Safety aka Section 16 Pit) On behalf of Lafarge West, Inc. (Lafarge), I am writing to provide an update regarding future plans for the two Bluestone Pits operated by Lafarge. In a previous letter to you, dated April 28, 2011, I provided a preliminary estimate of the cost to install a liner at these sites; Lafarge anticipated that installation of such a liner would be required in order to maintain compliance with Division of Reclamation, Mining, and Safety (DRMS) requirements. After subsequent research and internal discussion by Lafarge, the plan for these sites has changed. The Bluestone Pit (M1991035) will be graded to backfill all existing ponds to a depth of two feet above groundwater. The north pond will be the only one that is not backfilled; this particular pond was created by others long before the mining permit was issued and has not been enlarged by Lafarge's operations. As shown in the attached Figure 1, aerial photography taken prior to 1981 appears to show that the pond existed at that time, in which case it could potentially qualify for an exemption from administration pursuant to C.R.S. §37 -90- 137(11) assuming the pond was created in connection with sand and gravel excavation. Since the site was unpermitted when the pond was created, it is currently unknown if sand and gravel were being mined at the site. Regardless, it is Lafarge's position is that it is not responsible for reclaiming this particular pond and the current bond for the site (in the amount of $423,800) is sufficient to accomplish the proposed grading; therefore no additional bonding is required. The / Section 16 Pit (M1994045) has been inactive since Lafarge became the operator in 2002. The existing excavations at the site were created by others long before the mining permit was issued and Lafarge has not enlarged the existing excavations in any way. Similar to the other Bluestone Pit, aerial photography (see attached Figure 2) shows that this excavation was created prior to 1981 and therefore may also qualify for an administrative exemption assuming the excavation was created in connection with the extraction of sand and gravel. Since 1490 W. 121stAvenue, Suite 100 (303) 452 -6611 • Fax (303) 452 -2759 118 W. 6th Street, Suite 100 Denver, Colorado 80234 www.applegategroup.com Glenwood Springs, CO 81601