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c,E?v ED W STELIN WC.
<br />P.O. Box 3471 Rapid City, SD 57709-3471 (605)348-0244
<br />PO Box 88 Cortez, CO 81321-0088 (970) 564-1380 CELL (605) 390-7255
<br />o 1e`d office E-mail: WASTELINE66Daol.com or SDLiberty(a,aol.com
<br />n,
<br />?,`?ra n ofi R sa et Y
<br />01 SEP 2010
<br />Ms. Kate Pickford, Environmental Protection Specialist
<br />Colorado Division of Reclamation, Mining, and Safety
<br />Durango Office, via e-mail (hardcopy to follow)
<br />Subject: Adequacy Review, Noland Inc. Cedar Point 112© Permit Amendment AM-O1
<br />Application, M-1994-108 CEIVE-D
<br />Reference: Letter of 23 August 2010 SEP 1 3 2010
<br />Dear Ms. Pickford: r>?in;9 Ord
<br />As requested, this letter responds to the request for corrections and information.
<br />1. Please see Attachment 1 to this letter, which has the affidavit of publication for the
<br />public notice, the receipts for mailing public notices, and proofs of personal service.
<br />2. Please see Attachment 2 to this letter, which has a corrected Application page 1.
<br />Inadvertently, the numbers in item #3's second and third lines were reversed. The original was 60
<br />acres, 66 acres are being added, and the new total is 126 acres of the total parcel of land.
<br />3. 1 assume this is a reference to page 13 in Exhibit D. The total areas currently used and
<br />their status are discussed in Exhibit C (table for Sheet C-2, page 8) and Exhibit F (Map F-1, page
<br />28). Future use for the purposes listed (stockpile of pit run, product, overburden, soil, and water
<br />areas and controls) will not increase over the total area presently disturbed (46 acres) at any
<br />one time, and will generally be less than 40 acres total; areas in the process of reclamation are
<br />included in the 46 acres. In general, as discussed in various locations in the Exhibits, the amount
<br />of land required for each of the various purposes will vary over time from that currently listed on
<br />Map F-1; and some of the uses (such as water areas and controls) will be (or already are)
<br />permanent, some of which are listed on Map F-1. In general, approximately 10 acres will be in
<br />active mining areas, 10 acres used for various plants, and approximately 20 acres in use for
<br />stockpiles and water features, at any one time, with additional disturbed land in some stage of
<br />reclamation (backfill, grading, soil placement, seeding).
<br />4. Exhibit D, Page 15. The numbers were left out, and this last clause of Assumption #3
<br />should read: "...it is estimated that only 9.5 acre-feet of a required 23 acre-feet of soil (44%) will
<br />be available for final reclamation." (I do not know if there was a coding error in printing out the
<br />second bracket of "(44%) or just a typo - my copy doesn't have it, but I'm sorry for the typo.)
<br />To explain this: 46 acres of affected area (Assumption #3, page 14), at six inches thickness,
<br />requires 23 acre-feet of soil (37,100 CY in place) if the entire area requires soil for reclamation.
<br />Since some (3.1 acres, see Map F-1) of the 46 acres are to be reclaimed as roads and water
<br />bodies, and therefore requires no soil, only 21.5 acre-feet (3,700 CY in place) are needed.
<br />However, 24 acres of the affected area was mined pre-law by CDOT and other agencies, and
<br />soil was apparently removed together with construction materials. Because the average depth
<br />of soil in the remaining areas is only 4 inches, much less than assumed in 1994, there is only 44%
<br />(9.46 acre-feet, or 15,200 CY in place) of the total soil needed (of which 4.4 has been used on
<br />areas now being reclaimed). This is the reason for the use of clay and other overburden as
<br />bedding material as discussed further down on Page 15.
<br />5. Exhibit D, Page 15. ("STRIPPING:) Noland Inc. does not intend to sell any topsoil. However,
<br />much of the soil (A & B horizons) on site has roots of pinon and juniper or other plants, and has
<br />"larger materials" (such as cobbles or rock fragments/slabs, 4-inches, 6-inches or even larger in
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