2012-04-20_INSPECTION - M1977439

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OBSERVATIONS PERMIT #: M -1977 -439 INSPECTOR'S INITIALS: ECS INSPECTION DATE: April 16, 2012 This was a Succession of Operators inspection of the Home Office Pit, DRMS permit M1977 -439, a 112c sand and gravel permit now operated by Martin Marietta Materials (MMM). The inspection was conducted by Eric Scott of DRMS. DRMS visited the site with MMM representative Julie Mikulas at approximately 10:15. The site is currently active, and is also processing material from the adjacent Overland Ponds site to the south (M2002 -081). There are several issues that need to be resolved with the Home Office permit at this time. The first issue is that two unlined groundwater ponds located at the west end of the Home Office permit area have recently been re- permitted by the City of Greeley under the "Treiber Lakes" 112c permit (M2011 -049). MMM should submit an acreage release request to the Division ASAP to release this "Treiber Lakes" area from the existing Home Office permit. Permit boundary markers will also need to be placed to clearly delineate the boundary between the two permitted areas. The second issue is that the site is currently grossly under - bonded with regard to exposed groundwater in unlined ponds and excavations within this permit. There was previous discussion that 3 additional existing exposed groundwater ponds located in the southeast part of the permit area would also be incorporated into the new City of Greeley Treiber Lakes permit to reduce this liability; however this did not occur, therefore the bonding liability for those ponds remains with the Home Office permit. The SEO requires that operators comply with one of the four options outlined in the letter sent to all operators on April 30, 2010. If there is no permanent augmentation plan in place or in process for groundwater exposed at a site, and sufficient water rights have not been committed to such a plan and been approved by the SEO, the policy requires DRMS to bond to eliminate exposed groundwater liability at all permitted sites by backfilling excavations, or by constructing compacted clay liners or slurry walls that will pass the SEO testing process. At this time the unlined water bodies and excavations on site consist of the following: At this time DRMS will assume that there is sufficient bond in place, and material on site, to backfill the existing silt pond immediately south of the river and west of Taft Hill Road, and therefore it will not need to be lined. Because several of these large ponds are already full of water, construction of a slurry wall is likely the most cost effective way to meet the SEO requirement. Using the Division's current unit cost estimate for the Page 2 of 3 Unlined Pond/Excavation Description Approximate Surface Area (ac) Approximate Perimeter Distance (ft) 1 pond and one excavation north of Cache LaPoudre river and west of Taft Hill Road (combined) 30 5800 Excavation south of existing silt pond - currently being pumped dry 28.5 4875 2 existing ponds in Southeast end of permit area (combined) 62 7900 Existing pond directly east of office area - east of Taft Hill Road and north of nature trail 23 4800 Totals: 143.5 23,375 OBSERVATIONS PERMIT #: M -1977 -439 INSPECTOR'S INITIALS: ECS INSPECTION DATE: April 16, 2012 This was a Succession of Operators inspection of the Home Office Pit, DRMS permit M1977 -439, a 112c sand and gravel permit now operated by Martin Marietta Materials (MMM). The inspection was conducted by Eric Scott of DRMS. DRMS visited the site with MMM representative Julie Mikulas at approximately 10:15. The site is currently active, and is also processing material from the adjacent Overland Ponds site to the south (M2002 -081). There are several issues that need to be resolved with the Home Office permit at this time. The first issue is that two unlined groundwater ponds located at the west end of the Home Office permit area have recently been re- permitted by the City of Greeley under the "Treiber Lakes" 112c permit (M2011 -049). MMM should submit an acreage release request to the Division ASAP to release this "Treiber Lakes" area from the existing Home Office permit. Permit boundary markers will also need to be placed to clearly delineate the boundary between the two permitted areas. The second issue is that the site is currently grossly under - bonded with regard to exposed groundwater in unlined ponds and excavations within this permit. There was previous discussion that 3 additional existing exposed groundwater ponds located in the southeast part of the permit area would also be incorporated into the new City of Greeley Treiber Lakes permit to reduce this liability; however this did not occur, therefore the bonding liability for those ponds remains with the Home Office permit. The SEO requires that operators comply with one of the four options outlined in the letter sent to all operators on April 30, 2010. If there is no permanent augmentation plan in place or in process for groundwater exposed at a site, and sufficient water rights have not been committed to such a plan and been approved by the SEO, the policy requires DRMS to bond to eliminate exposed groundwater liability at all permitted sites by backfilling excavations, or by constructing compacted clay liners or slurry walls that will pass the SEO testing process. At this time the unlined water bodies and excavations on site consist of the following: At this time DRMS will assume that there is sufficient bond in place, and material on site, to backfill the existing silt pond immediately south of the river and west of Taft Hill Road, and therefore it will not need to be lined. Because several of these large ponds are already full of water, construction of a slurry wall is likely the most cost effective way to meet the SEO requirement. Using the Division's current unit cost estimate for the Page 2 of 3