2014-07-01_REVISION - M1979191 - Laserfiche WebLink

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Mr. Deuto July 1, 2014 Page 3 of 4 EXHIBIT G-Water Information(Rule 6.4.7): If the operation is not expected to directly affect surface or groundwater systems,a statement of that expectation shall be submitted,however,DRMS does not believe that this operation as proposed;which intends to mine on both sides and in close proximity to the Cache LaPoudre,as well as install four lined groundwater reservoirs into the alluvial aquifer,can accurately make the statement as supplied at the introduction to this section of the amendment. This would also be the appropriate section to provide the groundwater modeling data and interpretation,groundwater monitoring and mitigation plan,as well as the locations,boring logs and well construction diagrams of any piezometers located on site. Drawing C4 seems to indicate that there are 5 piezometers on the northern part of the site,but no data has been provided for them or any of the southern part of the site. Are there any piezometers on the Veldman portion of the site? Is there any current or historic water level data for the Three Bells site? Where was the data obtained for the"present conditions"groundwater contour map provided with the groundwater modeling? The text on Figure 5 of the groundwater model(drawdown predicted with liner for both parts of the permit area)is inconsistent with the legend. The legend states negative values indicate mounding(this seems to correlate with the figure)however the text under the figure states that positive values indicate a predicted rise in water levels. Please correct. It is worth noting for the purposes of your groundwater modeling that the site immediately to the south of the Veldman property(Kyger Pit)also has an SEO approved liner installed at this time. Please rerun the model for the Veldman property with this lined reservoir added. Has the model been run with the entire Three Bells site area as a whole entity or only in parts? DBMS will also require the installation,if not already present,of a sufficient number of properly located and constructed piezometers to monitor for possible excessive groundwater mounding and/or shadowing and off- site impact. Installing monitoring wells after a groundwater problem has been indentified has not been a viable strategy in the past-historic data is required for any useful groundwater impact evaluation. EXHIBIT L-Reclamation Costs(Rule 6.4.12): All information necessary to calculate the costs of reclamation must be submitted and broken down into the various major phases of reclamation. You must provide sufficient information to calculate the cost of reclamation that would be incurred by the state. The task breakdown seems reasonable,however,no information has been provided with regard as to how any of the quantity and unit price values shown in the table provided were obtained-considerable additional detail will be required. Several tasks appear to have been omitted,for example,QA/QC testing and documentation for the compacted clay or slurry wall liners(generally estimated at$650/day by DRMS),the re-spreading and grading of topsoil and preparation for seeding,and the maintenance and weed control of the vegetated areas after seeding and prior to release(commonly at least 2 growing seasons). It may also be useful to correlate the acreage data/tasks in the table to the phases of a reclamation plan map for clarity. EXHIBIT S-Permanent Man-Made Structures(Rule 6.4.19): Please note that roadways and above-ground or underground utilities(if present)within 200 feet of the proposed affected area are considered permanent man-made structures. In accordance with Rule 6.4.19,when mining operations will adversely affect the stability of any significant,valuable and permanent man-made structure located within 200 feet of the affected area,the applicant may either: (a) Provide a notarized agreement between the applicant and the person(s)having an interest in the