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f <br />• ~~III~I~~~I~~~~~I~~ <br />STATE ~ CCJ~UI~y~ <br />DIVISION OF h11NERALS AND GEOLOGY <br />Deparlmenl of Nomral Resources RECEIV \~~ <br />1713 Sherman St., Room ? I5 ED <br />Denver, Colorado 8U?03 D I V I S I O N O F <br />Phone. 003) 8fiG-7567 DED p s z0~/Q MIN & R A L S <br />FAX. 003) 83?8106 G E O L O G Y <br />December 4, 2000 Olvlsl0g0tMigeralaehdGaNOg~~.;--`i,-.~~ RECLAMATION <br />, MI NING•SAFETY <br />Mr. Timothy M. Scanlon ~-" " ~ ~ r `• ~ 'Y~ <br />Bill psrens <br />J and K Limestone Products, LLC. Ip _-. eoverno, <br />1410 County Road 2 East ~~"-' ~~~~ 1-' e,eFL.w,l~ne. <br />Monte Vista, Colorado 81144 yC,~ i-~,; J~ p° ~ Execuli°eD.,e°°` <br />/trlri/~[DDI ~ hf,chacl B. Lonl; <br />Ir rr Dici>ron Direclnr <br />RE: Villa Grove Pit, File M-2000-116, 112c Application Second Adequacy Review <br />Dear Mr. Scanlon: <br />The Division has reviewed your November 29, 2000 response to the preliminary adequacy review <br />for the Villa Grove Pit 1 12c permit application. The Division cannot approve the application until <br />the comments listed below have been adequately addressed. Please respond as soon as possible, <br />or at least by December 15, 2000, so the decision due date set for December 26, 2000 can be <br />met. If you cannot adequately respond by December 15, 2000, please submit a written request <br />for an extension of the decision due date. Please be aware, if your response, or a written request <br />for extension of the decision due date is not received, by the Division, by December 15, 2000, <br />this application may be denied. <br />ADEQUACY REVIEW COMMENTS <br />1 - 2, Response acceptable. <br />3. Original comment - P/ease demonstrate that the buffer zones wi// be adequate/y sized to ho/d <br />the amount of topsoil to be stockpiled there. <br />The response to this comment is not adequate. Proposing to stockpile 13, 310 cubic yards of <br />topsoil in a 1,000 ft. long x 30 ft. wide x 12' ft. high stockpile would require that the <br />stockpile be built nearly to those dimensions with vertical sides and squared off corners. The <br />topsoil stockpiles are most likely going to be in place for many years and must be protected <br />against erosion and weed infestation, neither of which are feasible with near vertical side <br />slopes (assuming topsoil could be stockpiled in this manned. The Division recommends that <br />topsoil be stockpiled with 3:1 slopes. Though steeper side slopes may be approved, they <br />must be stable and protected against erosion and weed infestation, preferably through <br />establishment of desirable/beneficial vegetation. <br />Though the mining and reclamation plans specify concurrent reclamation they also specify that <br />a minimum of 20-24 acres of pit floor area will be necessary for concurrent reclamation to <br />occur. That acreage is equal to the entire pit area minus the buffer zones and the 11 acre <br />initial processing area. In other words, the entire pit would be stripped of topsoil before any <br />concurrent reclamation would take place and concurrent reclamation would start when <br />excavation of the initial processing area was initiated. Therefore, based on the currently <br />proposed mining and reclamation plans, all the on-site topsoil would have to be stripped and <br />