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fro.-. ~IJ(Z (2eSvrcrces ,~,nc., <br />l <br />April 18, 2006 <br />Steve S. Shuey /,, <br />jp Division of Minerals and Geology <br />Grand Junction Field Office <br />101 South Third Street, Room 301 <br />Grand Junction, CO 8150] <br />,,_ <br />1 <br />Received <br />APR 1 9 2006 <br />Grand Junction Feld Office <br />Division of Minerals & Geology <br />./ / .~ <br />RE: Benson Brothers Red Shale Pit, File No. M-2005-071, Preliminary Adequacy Review, Response 2 <br />Deaz Mr. Shuey: <br />I wilt address the remaining Adequacy Issues in the order that you presented them. <br />Item 6. The silt fence that was outside the permit boundary has been relocated inside the boundary on the <br />Mining Plan Map. The drainage from above the process azea will be duetted under the process area fill <br />by a 12" pipe placed in the existing drainage before fill operations to create the process area. The length <br />of the pipe will depend on exact location of fill placement.. This pipe should transport any stormwater <br />from undisturbed areas above the process azea and is shown on the revised map. The process azea and <br />disturbed slopes above it aze in highly fractured and porous material. Based on experience at the previous <br />Benson Brothers Red Shale Pit, which was about 0.7 miles east of this site in similaz material, we <br />anticipate very little stormwater runoff from these areas. Silt fence and straw bales installed according to <br />Section 208 of the Colorado Department of Transportation Standazd Specifications for Road And Bridge <br />Construction should be adequate to control what little runoff occurs. The 24" culvert size chosen for the <br />haul road crossing in the normally dry drainage should be more than adequate to pass projected flows in <br />that drainage. There is a dry pond across that drainage on Red Canyon Coal Mine Property up-gradient <br />from this site that has a 10" culvert for a drain. Culverts down gradient in the same drainage have 18" <br />culverts at road crossings <br />Item 11: Benson Brothers has decided that, due to security concerns, there will be no on site storage of <br />fuel in this operation. Equipment and the generator will be fueled daily as needed from mobile fuel <br />transfer tanks tamed on various company vehicles. This approach has been working well for them at <br />other crusher sites. <br />Item 13: The average annual rainfall in this area is 14 to 18 inches, with 35 to 40% of that coming as <br />snow fall:`The greatest24-hour storm eventwe could find record of in the area was 2.18" at Cedazedge <br />on October 13, 1957. Stormwater from undisturbed areas will be directed azound or through the disturbed <br />azeas with berms of piping as previously described. The disturbed areas are very porous and we expect, <br />from experience at Benson Brothers previous Red Shale Pit, that most stormwater will percolate into the <br />ground and not run off. We believe that silt fencing as described in Section 208 and subsection712.08(b) <br />and erosion bales(straw bales) as specified in Section 208 of the Colorado Department of Transportation <br />Standard Specifications for Road and Bridge Construction will be adequate to control what runoff may <br />occur. <br />Item 14: Weed control will be accomplished by applying herbicides according to manufacturers <br />directions using a back pack sprayer. The site will be visually surveyed, at least monthly during the <br />growing season, by a person qualified to identify weedy species, <br />