Laserfiche WebLink
iii nuiiiiiiiu iii <br />STATE OF COLORADO <br />MINED LAND RECLAMATION DIVISION <br />Denv?r. CG EOc"9J <br />?63 666 3s6~ <br />F.. ~~~ EZ' ~ ._ <br />GATE: May 7, 1550 <br />JF~-n/.r <br />t - <br />z ~I.w <br />:~ <br />re'6 <br />-r. =.Td <br />rn..rna~ <br /> <br />T0: hike Long and Fred Banta <br />FROPi: Cathy 8egej anc Susan Pioury <br />s.JJ <br />kE: Rockcastle Reclamation Proposal of 5/1/90, <br />Grassy Gap Ftine, C-81-0`s9 <br />We have nevie~+ea the Rockcastle proposal. As we will ooth be out of the <br />office until Play 14, i59U, we offer the following comments for any <br />neyotiap;ions that occur with Mssrs. t~assey & Anderson curing our absence. <br />There acre a number of deficiencies with their proposal, as itemized belo~+. <br />- Tho' plan proposes that Rockcastle not pursue AC Z's previcus <br />recommendations to stabilize the Pit 4 road as they feel the road no <br />longer has stability problems. The stability study specifically <br />identified areas of instability and proposed toe buttresses for areas <br />th~rt appeared to ue experiencing rotational or slab type slides. We do <br />no't feel that it is acceptable to have the Division assume this liability <br />vri':hout installation of the buttresses. They propose to have ACZ study <br />thin road again in hopes they can demonstrate that it is now stable. It <br />seems inefficient to pay the same folxs to study t;re same area twice but <br />it'; their Dime. We do not agree that the performance of the slopes <br />dub•ing the past few dry years is indicative of long term stability. <br />- Rockcastle does not want to satisfy Stipulation 5, which requests a <br />stirbility analysis and remediation program for Pits 5 and 6 until Pi td 4 <br />reclamation is complete. It appears that Rockcastle is buying time'~a-s we. <br />do not understand what other activity Rockcastle is proposing to do in <br />ad;riition to this study, which would require waiting until September or <br />Ocl;ober. In addition, they never commit to conducting any remedial <br />activities indicated as necessary by their study. We feel it would be <br />pr~ldent to conduct such activities when the equipment is available on <br />si':e this summer. In order for this to happen, the study must be done <br />Sonn. <br />We do not believe that a $SU,000 forfeiture is adequate. They currently <br />estimate their maintenance cost at $7,000/year. We have four to five <br />im~~oundments and associated ditches and furrows to reclaim, and total <br />re'+egetation failure at Pit 4 and 25% of the rest of the sites would cost <br />$4D ,200 by today's costs. <br />It~is not clear that Rockcastle intends to pay the civil penalty on the <br />bond NOV (C-50-007). <br />