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IFw <br /> CLOSE CONSULTING GROUP <br /> Environmental Science&Engineering <br /> RECEIVED <br /> March 17,2016 MAR 2 3 2016 <br /> Mr.Adam DeVoe DIVISION OF RECLAMATION <br /> Lewis Roca Rothgerber Christie LLP MININGAND SAFETY <br /> 1200 17th Street, Suite 3000 <br /> Denver,CO 80202-5855 <br /> RE: Groundwater Monitoring Evaluation for the GCC Pueblo Plant and Quarry <br /> Dear Mr.Devoe: <br /> Close Consulting Group LLC is pleased to provide this letter report for the above-referenced project. The <br /> Colorado Division or Reclamation,Mining and Safety(DRMS)is requesting additional assessment and <br /> justification regarding the technical feasibility and scope of groundwater monitoring. The purpose of this <br /> report is to review the hydrogeology and past and current groundwater monitoring at the GCC Rio Grande, <br /> Inc.Pueblo Plant(GCC)and develop findings,alternatives and recommendations to satisfy regulatory and <br /> risk management decisions. <br /> SITE DESCRIPTION AND BACKGROUND <br /> The attached Figure 1 illustrates the site features and mine plan,and Attachment A provides available local <br /> and generalized stratigraphic sections. GCC quarries the Fort Hayes Limestone Member of the Niobrara <br /> Formation,and began extraction and processing in 2007 and 2008,respectively. GCC is permitted to quarry <br /> the Fort Hayes Limestone and approximately 5 feet into the Codell Sandstone,which has also been described <br /> as hard,brown sandy petroliferous limestone and a platy and shaly sandstone(Attachment A). Site drilling <br /> logs indicate that the Codell also contains multiple shale or sandy shale lenses. Initially,GCC planned to <br /> remove and processed Codell Sandstone,but that was eliminated near the onset of operations when further <br /> testing determined the material was not beneficial to process. GCC extracts only the Fort Hayes, leaving the <br /> bottom one foot of the limestone. <br /> Regionally,the Juana Lopez Shale Member separates the Fort Hayes and Codell members,but is only about <br /> 2 feet thick. Locally,the Juana Lopez Member is largely absent due to an erosional unconformity,such that <br /> the Fort Hayes directly overlies the Codell(Collum,2000). Underlying the Codell is approximately 400 feet <br /> of upper Cretaceous members,principally composed of dense shales,which provides an effective hydraulic <br /> barrier from the underlying Dakota Sandstone aquifer. <br /> The Fort Hayes and underlying strata strike essentially perpendicular to the mine panels and dip <br /> approximately 2.7 degrees to the northeast parallel to the mine panels(Figure 1). The approximate current <br /> extent of mining is also shown on Figure 1. During recent mining a fault was encountered near the middle of <br /> the Years 6- 15 mine panel. This fault is a normal dip-slip fault,trending southwest to northeast,with <br /> approximately 10 or more feet of vertical displacement that currently appears to increase to the northeast. <br />