2013-03-12_REVISION - M1982112 - Laserfiche WebLink

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March 11, 2013 37 East Colorado Avenue • Denver, Colorado 80210 - 3105 • (303) 906 - 8096 Division of Reclamation, Mining and Safety Room 215 1313 Sherman Street Denver, CO 80203 RE: Letter of February 28, 2013, to Rick L. Hunt regarding Miller Gravel Pit Permit no.: M1982112 Dear Sirs: Your letter has been provided to me for response. It is believed that your suggestion that this operation requires a TC or IS is in error for the following reasons. Although the annual reports and amount of activity at the site may superficially appear to justify altering the permit to temporary cessation or intermittent status, such a change would be quite detrimental to the operation. In fact, this pit is constantly available for production and as a recent average about 500 tons per month are sold from the pit. In the past, this pit showed considerably more activity than it has over the last three or four years, but that is primarily due to the downturn in the economy and the lack of demand for large volumes of material. In the past, this pit mined, processed, and sold much larger volumes than is currently the case. But with low demand, the pit has had to alter its mode of operation. Now, a large volume of material (25,000 to 30,000tons) is produced and stockpiled at a time. Then the mining and processing portion of the operation shuts down until the stockpile declines or an order for a large volume of material is received. At that point, the mining and processing is restarted to either rebuild the stockpile or to fulfill the large order. This pit is open for business every day and if an order for construction fill or some other product is received, personnel are immediately sent to the site to fulfill the order. Schmidt Construction Company who operates the pit, in fact, pays Mr. Hunt $150 per day for use of his scale whether it is used or not. That clearly indicates the operation is open for business everyday. This site is also the primary aggregate source for supplying the asphalt batch plant in Castle Rock operated by Schmidt. When asphalt is needed aggregate is taken from this site to supply the needs for producing the asphalt. Once again, because of the downturn in the economy the demand for asphalt in construction, repaving, etc. has also declined so the demand is not as great as it has historically been. It also needs to be pointed out that when an area is completed with mining, that is, when the working face will no longer be operated, that area is graded and reclaimed However, because the rate of mining has declined working faces tend to last longer than was formerly the case. But that does not mean the pit sits neglected. Care is taken to insure that sediment and erosion is controlled. Temporary cessation is more appropriate for operations that have really ceased operation for a period of time. That is not the case here. Although having an intermittent status might be more appropriate, that is also restrictive on the nature of how this pit works. In both cases, when a large project requires material it is more often than not on a very tight time frame and cannot wait for an approval of a request to remove the pit from temporary cessation or to undo some temporary provision so mining can proceed. Being able to promptly respond to the orders for material is the very essence of this operation and restrictions on that responsiveness would likely result in much loss of business as customers would go elsewhere for their material due to delays with obtaining material here. Thank you for your consideration and it is hoped that you can now see why TC or IS is not appropriate. cc: Rick Hunt, Scott Davis, Donald Opheim Mark A. Heifner 6a\ RECEIVED MAR 12 2013 Division of Reclamation, Mining & Safety RECEIVED MAR 12 2013 Division of Reclamation, Mining & Safety