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HomeMy WebLinkAbout20013511.tiff • cl Epvirouwept , Inc. LARRY E. O'BRIAN 7985 VANCE DRIVE. SUITE 205A FOUNDER ARVADA,COLORADO 80003 303-423-7297 FAX 303-423-7599 May 22, 2001 4L''_. _/-<I Clerk to the Board Weld County Commissioners Office 915 10th Street, 3rd Floor Greeley, Colorado 81003 Re: Application for a Mined Land Reclamation Permit Dear Sir/Madam: We are delivering to you here with a Technical Revision adequacy review response packet for the S & H Mine to be operated by Platte Sand & Gravel LLC. This copy of the adequacy review packet is delivered to you pursuant to 34-32 .5-112 (9 ) (a) , Colo- rado Revised Statutes 1995, as amended. This packet must be kept with the original book, for public review until the permit has been approved by the Division. We will contact you once it is and make arrangements to pickup this copy. Please acknowledge receipt of the copy of this packet by signing in the appropriate space provided below and returning one copy of this letter to the person delivering the book. This will be submitted to the Division of Minerals and Geology to prove this packet was delivered to your office. Yours truly, ENVIRONMENT, INC. Stevan L. O'Brian enclosure RECEIVED THIS-Y DAY OF /''(c rf-. , 2001, one copy of an D.M.G. Adequacy review pieket for above mine. Wel County Clerlcto the Board By / [' ,2F a ' A/2'L 17.," „_ a �cvl- 35'1 - / / Pi/54/5 • • •Epvirouweut , Inc. LARRY E. O'BRIAN 7985 VANCE DRIVE,SUITE 205A FOUNDER ARVADA, COLORADO 80003 303-423-7297 FAX 303-423-7599 May 22, 2001 Ms . Erica Crosby Division of Minerals and Geology 1313 Sherman St. , #215 Denver, CO 80215 Dear Erica; RE: Platte Sand & Gravel LLC S&H Mine, Permit # M-2000-158 Continuance of hearing date On behalf of Platte Sand & Gravel LLC (PS&G) , I am responding to the Technical Revision review sent to Mr. Hoffschneider last week. This response addresses and expands on the plan submitted on April 20, 2001 . It specifically addresses the four bullets on the first page of your review. During design and installation of the armoring, whether on the lake banks or river, PS&G will follow the guidelines in the INSTREAM AGGREGATE AND RECLAMATION GUIDANCE DOCUMENT. If subsequent changes are required to be made to this plan, PS&G will submit the proposed changes to the Division of Minerals and Geology review and approval. Initially the site was looked at to identify areas of excessive scour, the depth and velocity of floodwaters across the mined area and along the river banks that might cause problems . Identified were areas along the river and on gravel pit slopes that are either lateral berms or peninsulas perpendicular to the river, where flood water could erode the banks and cause damage to structures . These areas are where armoring will take place as mining progresses . In addition, there may be areas on the river side of the bank that may need armoring to protect the site. Prior to mining within 400 feet of the river Platte Sand & Gravel will prepare a map showing the area where potential erosion could cause the river to enter the excavation area. For example, there are three possible areas that may be subject to erosive flows during a flood. They are the outside edges of sharp bends in the river channel, adjacent to Meadow Lake, Sharkey's Lake and Longhorn Lake. The map will be submitted to the Division for review and approval. • ENVIRONMENT, INC. • PAGE 2 MAY 22, 2001 In the areas where armoring is necessary, the gradation of the soil and subsoil (sand and gravel) will be examined along with vegeta- tion characteristics to determine if the erosive power of the flood will cut into the vegetation and soil. In those areas were it is determined that erosion will occur the operator will place riprap material, that cannot be lifted and moved by floodwater. This will prevent erosion and down cutting on those slopes subject to scour. As noted in the Division's review, we will use a D,p = 24 to fulfill this requirement. For this mine Pickett Engineering opted to use a 100-year event as the design criteria for the plan. This is consistent with the standard national procedures adopted by the Federal Emergency Manage- ment Agency as the base flood for purposes of floodplain management. PS&G recognizes that the erosion controls installed are only intended to be effective up to the flow rate associated with the design event. There may be residual losses from extreme flood events, above and beyond those for which mitigation is cost effective. As noted in the original flood plain information the 100-year floodwater velocity at the south end of this mine will be from 1 .5 to 2 . 0 feet per second up to 3 .6 feet per second at the north end of the site. The increased flows and velocity on the upper end are north of the confluence of the South Platte River and St. Vrain Creek. These velocity estimates are on a macroscopic scale, and were the average velocity of the large volume of water flowing through the mine reach during a 100-year flood. Since no specific velocities are known, the operator will follow the general guidelines and conservative formulas outlined in the guidance document. The map in the Pickett study has been revised to include the areas that may be affected by a 100-year flood. These areas incorpo- rate the areas outlined in the division letter, in addition to those shown previously. While the original plans were based on a qualita- tive analysis of the river and floodplain, the operator will begin to develop the qualitative analysis as mining progresses . Using the information provided in the review letter, the map was revised to extend the armoring around the south side of the slope in Meadow Lake. Pit slopes that intersect with natural swales, abandoned tail water ditches, et cetera, will also be armored. These areas do not readily show on the map so as the site is developed, they will be identified and armored using the design criteria outlined in this plan. The last areas of concern are the gaswell pads and access road alignments in Sharkey's Lake where they are in close proximity to the River. • ENVIRONMENT, INC. • PAGE 3 MAY 22, 2001 Attached are typical cross sections that will be used to design the bank armoring. They are from the Division of Minerals and Geol- ogy's Instream guidance document (Figure D-5, Figure D-7 , and D-8 ) . Proposed armoring plan Pickett Engineering used a D90 equal to 24 inches and the Divi- sion suggested the minimum thickness should be D90 x 2 .0 for the pit banks and D50 x 1 .75 to DSO x 3 .0 on the river banks . These guidelines will be followed. If a change is necessary, revisions will be submit- ted to the Division for review and approval. Armoring will be doubled on each end of a reach whether in a lake or on the river, if it ends on a natural bank. Pit Slopes The pit slope armoring will be placed on slopes no steeper than 2 .5H to 1V as shown on the guidelines. The thickness will be calcu- lated by using D50 x 2 .0 to determine the thickness. The applicant proposes using concrete rubble as riprap material. This material is readily available to Platte Sand & Gravel and has been proven effec- tive on other mines throughout Colorado. The concrete rubble is angular, durable, and non-slaking in nature, but physical testing and documentation showing that it meets the requirements and the gradation specification will be conducted on the material prior to use on each 500-foot section. Physical testing will include a slake test and an abrasion test to be sure the rubble is suitable for riprap. Any unsuitable material will be used as fill as explained in the permit application. The records of the test results will be kept in the corporate offices for review. Prior to placing the riprap the applicant will conduct at least one gradation test for each 500 linear feet of riprap installation to determine if the in situ material is suitable for the bedding. This will be done to demonstrate and document that the filter bedding is compatible with the riprap. This bedding will be a filter blanket of gravel, or sand and gravel that will prevent soil movement into or through the riprap. It is possible that the in situ materials will create suitable bedding, particularly on the pit slopes since pit run sand and gravel usually makes a good filter blanket. The armoring will cover a band from the existing ground surface to an elevation 3 feet below the river invert on any gives section and will be keyed in or doubled per the design specifications provided in the Division' s guidance document. On the ends of the armored pit banks the depth • • PAGE 4 ENVIRONMENT, INC. MAY 22, 2001 will be doubled in accordance with the guidance document's recommenda- tions. River bank armoring The armoring will be done along the river channel side of the bank, but only where mining is within 400 feet of the river. A map will be prepared and submitted to the Division showing the areas of concern for review and approval prior mining within 400 feet of the river. In the areas where armoring is required, Platte Sand & Gravel will follow the guidelines published by the Division. In general, a D50 x 1 .75 to 3 .0 will be used depending on the site specific require- ments in each reach being armored. If an armored reach ends on a natural riverbank, the Division' s published guidance for riprap end protection will be followed. This calls for doubling the riprap thickness at the ends of an armored reach that begin and end on natural banks or extending them to non erosive areas . The riverbank armor will be keyed five feet below the river bed or, alternatively, extension of a thicker (doubled) layer of riprap into the channel bed will be done as suggested in the guidance docu- ment. (Figures D-5 and D-8, DMG, 1998, copies attached) . There may be areas where keying the toe into the river bottom is not practical so both methods may be used depending on what is encountered in a reach. A granular bedding and filter will be placed under the rip rap. As noted above the in situ material will be tested at each site to determine if it is acceptable. Prior to installing riprap into areas of a cut bank, it will be graded to no steeper than 2 .5 : 1 and granular bedding and filter subgrade will be placed. On the areas of riprap above the normal highwater line the applicant will use a method of slope protection measures found in section 2 .3 .2 of the Urban Drainage and Flood Control guideline document. In general, a cover of dirt will be placed over the riprap and willow stakes and grass will be planted to lock the dirt in place. The willows will eventually spread and create a vegetation blanket that slows flood water along a bank reducing erosion. The timetable for riprap installation The timing for rip-rap placement depends on how fast the mine develops . The operator will make every reasonable effort to complete final lakeshore protection measures for all such areas prior to April 1st of each year. The lakeshore sensitive areas are those areas depicted in green on the map included with this response. Map Exhibit C-1 show how the mine will look approximately 15 years after mining ENVIRONMENT, INC. PACE S MAY 22, 2001 starts . A line has been added showing when planning for riprap work will begin. Prior to Platte Sand & Gravel reaching this line a map showing where river bank armoring will need to be done will have been submitted and approved by the Division. Also at that time, the bond will be evaluated to determine the cost to rip-rap the lake banks that will be created in the near future. At no time will mining take place within 400 feet of the river without first having armored the banks on the riverside that are subject to erosion and less that 400 feet from the excavation area. This line is at least 430 feet from the closest structure that would be affected by down cutting if the river flooded. Note that there are no lake banks next to a structure that could be affected if flood water entered the excavation area and that mining will not be within 400 feet of the river. Armoring on pit side banks will begin once 500 feet of final shore line has been created in an area needing armoring. No more that 500 feet of erosion sensitive final pit perimeter, will be exposed without armoring, at any one time during the life of the mine. Armoring will be done concurrent with reclamation so PS&G stays within the 500-foot limitation. The bank sloping will be done prior to armoring, the gradation test will be done to see if the in situ material is acceptable, and the riprap will be placed. Resoiling and revegetation will then take place according to the proposed plan. Mining is not expected to reach an area where armoring of lake banks will be necessary for 10 or more years . Armoring will be completed prior to mining within 400 feet of the river where the armoring is needed. The areas that need to be armored will be identified on a map that will be submitted to the Division for review and approval. The operator will continue to monitor the river banks as mining progresses and if additional areas are identified after the first map is submitted a revised map will be prepared and submitted for Division review. On a conservative side mining is not expected to reach the river area within the first 10 years of the mines life. The estimated cost Review of the Division cost estimate and methodology is accept- able to the applicant. While they believe they can do it at a lower cost, it is understood that the cost for the Division to do the job is greater than the applicant's cost. The applicant is choosing to use concrete rubble but that material may not be available to the Divi- sion. Thus, using quarry rock is the only alternative when calculat- ENVIRONMENT, INC. • • PAGE 6 MAY 22, 2001 ing the bond. No bond change will be necessary for river bank armor- ing since it will be completed before mining is within 400 feet of the section needing armoring. Under the plan presented above, calculating a bond to increase to build armor on lake banks will not be necessary for at least 5 years and costs will have changed over that time. I have repeated the Division's rational for bonding, but choose to leave material and delivery costs out of the formula so they can be included when the time comes to recalculate the bond to cover bank armoring. Base line data for bond calculation: Cost of Rip Rap = C„ Cost of bedding = C,, Placement cost of Rip rap = Prr Haul cost Rip rap = H, = Haul distance x per ton cost Haul cost bedding = H,, = Haul distance x per ton cost Rip rap volume per linear foot 11.4 tons Bedding volume per linear foot 2.9 tons Riprap Haul distance = 60 miles (one way) Bedding Haul distance = 10 miles Formula: (Crr x 11 . 4T)+(H, x 11 .4T)+(P,: x 11 .4T)+(Cb x 2 .9T)+(Hb x 2 . 9T) If, as mining progresses, the locations and amount of riprap needed in a particular area differs from the commitment PS&G is making in this response they will submit a revision to the Division for review and approval . Thanks for your help and if you have any questions call me at 303-423-7297 . Respectfully Submitted, Environment, Inc. Stevan L. O'Brian President enclosures cc Platte Sand & Gravel LLC . Weld County Clerk file a)TYPICAL CHANNEL RIPRAP SLOPE PROTECTION 1' FREEYDARD ---f- II) YR. 1A-HR•• W4. r$ Lit YR. :i• 176 a DSO 11 �. t.0'YW. GRANLEAR BBDDWG— AND FILTER • 3.0 c D 0'MIN. ~MXi • r b)TYPICAL RIPRAP AND VEGETATION SLOPE PROTECTION re FREEBOARD • IO YR Z4-HR W-S- ij . „--- '\I 6-- BOB. AND 'S�'Ct LAYER OVERLYDIG TOPSOIL.*AP 1-0• i YR.24-HR WS. 111& I.TS i 050BxLaD4 01 •S'W N, t } • ILO r 1.10.0 l,.GRANOLAR BEDORIG AND FILTER SOU.AP WX[p IN WITH ��SO4'AND SEED INCIGDING WILLOW SLASH• • c)TYPICAL PITSIDE RIPRAP SLOPE PROTECTION rTOP OF RIIVERSIDE BERM MI _ II GRANULAR • PIT N.W.L REDOING AND FILTER i_O a on• •i. \ RIVER IHV{:RT W.S.-Water Swface t3 MIN_ N.W.L:NaDlrai Watrr Laval Figure D-5 taint-�Fa•1 Rip-Rap Slope Protection •;i•.'r r.(:.;"...:•:••:.....:',. ... . .:� • L 6d'RevelMont in'•'. • , t ..:Non-P54.11.1"4,. . O :jil O ii: 4 a. • :;, :y ., rj 4T go .::'r,'' r,fk I / v. • :tom b•r resat)1 a b Figure D-7 Plan Views of End Protection Configurations: a) Extension. Out of the Zone of Erosion with a Potential Reduction in Thickness, s.naasn..F7r,.px and b) an Increase in the Thickness at the Ends of the Revetment Rfprap• Water Lever E:r'/ —Filter BackilEl to Original .•.• Bed 4, �•�!/ •� •�.a1I�,,.R+{TL F!:Sri.>'u: 2•.m«^.:,Fn::• t--------Thickness Depends on Potential for S^ix,r � a Figure 0-6 Cross-Sections of Toe Protection. Configurations: a) Extension of the Riorap Below the Dry Bed and Balling, and b) Placement of Extra Maters! 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