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Mr. Paul Bruss <br />September 15, 2015 <br />Page 2 of 5 <br />Valco and the District are still in negotiations and it is anticipated that a water court <br />application, and a companion SWSP request, may not be filed for 1-2 years. Accordingly, <br />Valco seeks a 2 -year SWSP approval to finish development of these plans for permanent <br />augmentation. <br />In accordance with the letter dated April 30, 2010 from the Colorado Division of Reclamation, <br />Mining, and Safety ("DRMS"), all sand and gravel mining operators must comply with the <br />requirements of the Colorado Reclamation Act and the Mineral Rules and Regulations for the <br />protection of water resources. The April 30, 2010 letter from DRMS requires that you provide <br />information to DRMS to demonstrate you can replace long term injurious stream depletions <br />that result from mining related exposure of ground water. The DRMS letter identifies four <br />approaches to satisfy this requirement. Approach nos. 1 and 3 require bonding to ensure the <br />pit can be backfilled or lined. The 4th approach requires documentation to identify what <br />water rights or other permanent water source will be dedicated to the SWSP to assure that all <br />permanent depletions from either an unforeseen abandonment of the site by the Applicant or <br />as a result of long term ground water exposure after completion of mining and reclamation <br />will be replaced so as to prevent injury to other water rights. <br />While it is the understanding of this office that Valco is in the process of arranging for <br />permanent augmentation coverage, there was no information included with the request to <br />document how Valco is currently in compliance with the April 30, 2010 letter from DRMS. <br />Any SWSP renewal request must contain documentation to show that Valco is currently in <br />compliance with Approach Nos. 1, 3, or 4 of the April 30, 2010 letter from DRMS. <br />DEPLETIONS <br />The Canon City East Pit is presently undergoing reclamation in accordance with the DRMS <br />permit. The only depletions covered under this SWSP are evaporative depletions from onsite <br />gravel pits shown in Figure 1. Evaporative depletions were calculated using the maximum <br />surface area of the pit, which is 22.6 acres (7.2 acres of post -1981 exposed ground water). <br />Therefore, based upon net annual evaporation of 3.1 feet per year, the maximum total <br />annual evaporative depletion will be 22.3 acre-feet (see Table 1, attached). <br />Depletions have been lagged back to the Arkansas River using a Glover analysis with the <br />following parameters: <br />Distance from river: 510 ft <br />Distance from alluvial boundary: 1730 ft <br />Transmissivity: 26,000 gpd/ft <br />Specific yield: 0.2 <br />As shown on the attached Tables 2a-1 and 2a-2, you have calculated the total lagged <br />depletions to be 22.96 acre-feet from June 1, 2015 through May 31, 2016 ("Year 1 ") and 22.32 <br />acre-feet from June 1, 2016 through May 31, 2017 ("Year 2"). <br />/oF' colo <br />1313 Sherman Street, Room 821, Denver, CO 80203 P 303.866.3581 F 303.866.3589 www.water.state.co.us I rye k oI <br />* <br />1876 <br />