2018-03-15_REVISION - M2008017 - Laserfiche WebLink

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J&T Consulting, Inc. March 15, 2018 Page 3 of 4 Rule 3.1.6 (1)(b), "compliance with applicable federal and Colorado water quality laws and regulations, including statewide water quality standards and site-specific classifications and standards adopted by the Colorado Water Quality Control Commission." This site is in a non -classified area, and therefore the Table Value Standards of the statewide Interim Narrative Standard from WQCC Regulation 41 apply to groundwater for this site. The permittee should include a plan to characterize background groundwater quality, and be able to demonstrate with defensible groundwater monitoring data that these standards have not been exceeded during mining and reclamation operations. EXHIBIT 3 - Vegetation Information (Rule 6.4.10): Reference is made to a letter provided by US Army Corps of Engineers stating that wetlands identified during the site study were determined by USACOE to be non jurisdictional, however, that letter was not part of the application as submitted - please provide this documentation. EXHIBIT L - Reclamation Costs (Rule 6.4.12): DRMS is currently reviewing the Reclamation Estimate provided. Items identified at this time which will require modification include: 1) Costs associated with design and installation of pumping/water management structures, engineered flood control structures for lined reservoirs within the flood plain, and perimeter drains as stated in the comments for Exhibit E. 2) DRMS will not bond for the final slung wall configuration in "phases". The required bond for the construction of the final slurry wall configuration will be required to be posed before groundwater is exposed in any phase within that slurry wall (phases 1-4, phases 5-7). 3) Please submit documentation for the direct costs provided in Exhibit L. 4) You will be contacted if additional information is required as the adequacy issues are resolved. EXHIBIT S - Permanent Man -Made Structures Rule 6.4.19: DRMS considers the entire proposed permit area to be potentially affected area at this time. No evidence has been provided that any structure owners inside, or within 200', of the existing or proposed permit area have been provided with damage waiver agreements (other than the City of Greeley, Loloff Construction, and DCP Midstream as provided). This demonstration is required by DRMS prior to acceptance of a geotechnical stability exhibit such as the one provided for the first four phases of the proposed operation. DRMS cannot approve the permit amendment unless/until: 1) All structure owners within, and within 200 feet of the proposed permit area are provided with damage waiver agreements, and proof of this has been submitted to DRMS. To facilitate this process, please provide a detailed breakdown of all applicable structures by structure owners, and show the structures/locations on to a map depicting this information. Listing structures only by type, as submitted in Exhibit S, is inadequate. 2) Executed damage waivers for those structures have been received and submitted to DRMS, or a geotechnical evaluation has been conducted to determine that those structures that have not returned executed damage waiver agreements will not be adversely impacted by mining activity. The geotechnical assessment must provide information sufficient to demonstrate that the stability of any structures located within two hundred (200) feet of the operation or affected land will not be adversely affected. Please provide evidence (certified letter to structure owners) that a notarized agreement between the structure owners and the applicant was pursued. If an agreement is unable to be reached a geotechnical assessment may be provided to demonstrate that the structures shall not be damaged.