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OBSERVATIONS <br />PERMIT #: M- 1983 -090 <br />INSPECTOR'S INITIALS: ECS <br />INSPECTION DATE: January 10, 2013 <br />This was a routine site monitoring inspection conducted by DRMS at the LaPoudre Sand & Gravel site. The inspection <br />was conducted by Eric Scott of DRMS. DRMS travelled to the site with Mark Johnson of Bestway Concrete <br />approximately 1130. The site entrance is located at the southwest corner of Weld County roads 392 and North County <br />Line Road. This site is also adjacent to the Bestway North LaPoudre pit (M2000 -144). <br />DRMS toured the site with the Mr. Johnson. Current excavation activity in the mine is located primarily in the cement <br />plant area and on the adjacent North LaPoudre site. Cement production/recycling and sales of stockpiled material are <br />continuing on this site. The mining and reclamation of the eastern and southern (south of river) part of the permit area is <br />essentially complete although revegetation will need to be completed on the eastern portion of the permit. The slurry wall <br />surrounding the water bodies in the center of the site has been approved by the SEO's office. According to DRMS <br />records, no portion of this site has been released from the permitted area to date. A technical revision or permit <br />amendment will likely be required for this site to revise the existing reclamation plan to the current/proposed final site <br />configuration. <br />The bonding issue noted on the first page of this inspection report is a result of failure to address exposed groundwater <br />issues and the resulting bonding liabilities as described in the letter sent out to all operators in February of 2010. There is <br />a currently a significant amount of exposed groundwater at this site (approximately 32 acres), with 2 unlined ponds south <br />of the river and one unlined pond at the west side of the site near the site entrance. At this time the bonding liability for <br />this exposed groundwater has not been addressed. A similar exposed groundwater issue also exists on the adjacent North <br />LaPoudre site. <br />Any areas of exposed groundwater that are not currently part of a submitted or approved permanent augmentation plan <br />will need to be backfilled, or sealed from the alluvial aquifer with a clay liner or slurry wall that will pass SEO approval <br />criteria. As an alternative, Bestway Concrete may also commit sufficient water rights for all exposed groundwater to be <br />applied to a permanent augmentation plan for the site. This commitment of water rights would need to be made in an <br />approvable format to the SEO's office, and documentation of SEO approval would need to be provided to DRMS. At this <br />time, to avoid possible enforcement actions, Bestway Concrete will need to identify how each area of groundwater <br />exposed at the site will ultimately be dealt with and bonded for in a manner that will comply with the requirements of the <br />February 2010 letter by the corrective action date shown on the first page of this report (2/10/13). <br />DRMS will review the updated bond calculations submitted for the site by Bestway. DRMS may also calculate a new <br />bond for the site that will include the necessary modifications for addressing groundwater exposure and the associated <br />costs based on what methods Bestway chooses to address the exposure of groundwater at the site. When the appropriate <br />bond for the site has been determined, the updated bond amount will be specified in a forthcoming surety increase as <br />described on the first page of this report. <br />Inspection Contact Address <br />Mark Johnson <br />Bestway Concrete Company Inc. <br />301 Centennial Dr. <br />Milliken, CO 80543 <br />Page 2 of 3 <br />