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A10- , <br /> t�RUSH',I;- <br /> CONSULTANTS,INC. <br /> July 23, 2014 RECEIV <br /> Project 14109 ED <br /> 'Jul 24 ?n14 <br /> Mr. John Sliman <br /> Southwest Farms p Tlgy <br /> 1825 Chianti Court <br /> Pueblo, CO 81001 <br /> Re: Evans Pit#2 M-2000-041 <br /> Comments on Fremont Paving's Groundwater Monitoring Program <br /> Dear Mr. Sliman: <br /> We have reviewed the groundwater monitoring program(program)that was prepared for <br /> Evans Pit#2 and was recommended to the DRMS by Environmental Alternatives, Inc. We <br /> had previously reviewed Fremont Paving's draft groundwater monitoring plan and had <br /> provided comments to you in a letter dated May 20,2014. In our opinion the developed <br /> program is less technically robust than the draft plan,and the program has also identified <br /> additional issues with historical monitoring at the pit that need to be addressed. <br /> In our opinion,the program does not protect Southwest Farms(or other adjacent landowners) <br /> from groundwater impacts caused by dewatering of Evans Pit 42. Furthermore,it appears <br /> that Fremont Paving is using the program to recuse itself from liability for declining <br /> groundwater levels associated with these activities. The program uses much of its text to <br /> explain how: 1)alluvial groundwater levels can fluctuate because of pit dewatering, <br /> irrigation, climate trends, natural causes, etc.,2)pit dewatering has been occurring for many <br /> years and no background groundwater data was collected prior to the start of dewatering, and <br /> 3)no conclusive opinions can be drawn until many years' worth of data is collected. The <br /> program implies that even if the monitoring shows declining groundwater levels,this might <br /> be a long-term trend that would be occurring even without pit dewatering. <br /> In our opinion,identification of normal background groundwater trends is of vital importance <br /> prior to evaluation of impacts from pit dewatering. Ideally this would have been collected <br /> prior to pit dewatering or Fremont Paving would stop pit dewatering and allow the alluvium <br /> to recharge to static levels until adequate background groundwater data is obtained; however, <br /> we acknowledge that this is not practical. If there is insufficient background groundwater <br /> data available,we are of the opinion that Fremont Paving should initially be collecting as <br /> much data as practical to develop a database of background regional groundwater trends. <br /> 9800 Mt. Pyramid Court,Suite 330 303-225-4611 -phone <br /> Englewood, CO 80112 303-225-4615-fax <br /> www�h-consultants.com 866-900-1930-toll tree <br />