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Ms. Lindsay M. Griffith, P.E. <br />July 13, 2018 <br />Page 2 of 6 <br />SWSP OPERATION <br />Holcim's Portland Plant manufactures Portland cement, which involves quarrying of raw <br />materials such as limestone and silica, grinding, pyro-processing, and storing and shipping <br />activities. The Portland Plant uses raw materials obtained from the Holcim Quarry, which <br />operates under the Division of Reclamation, Mining and Safety ("DRMS") permit no. <br />M-1977-344 and is the subject of this SWSP request. Depletions within the mining boundary <br />consist of evaporation of water in the ponds and water pumped from the ponds for dust <br />suppression. <br />In accordance with the letter dated April 30, 2010 from the Colorado Division of Reclamation, <br />Mining, and Safety ("DRMS"), mining operators must comply with the requirements of the <br />Colorado Reclamation Act and the Mineral Rules and Regulations for the protection of water <br />resources. The April 30, 2010 letter from DRMS requires that you provide information to DRMS <br />to demonstrate you can replace long term injurious stream depletions that result from mining <br />related exposure of ground water. In accordance with approach nos. 1 and 3, a bond has been <br />obtained for $5,268,550 through the Division of Reclamation, Mining, and Safety ("DRMS") to <br />assure that depletions from groundwater evaporation do not occur in the unforeseen event, or <br />events, which would lead to the abandonment of the mining site. <br />DEPLETIONS <br />Depletions at the Holcim Quarry consist of evaporative losses from exposed water in the East <br />Pond (WDID 1205768, permit no. 76814-F), the North Pond (WDID 1205769, permit no. <br />76814-F), and the Glory Hole (WDID 1205772, permit no. 76814-F), and operational losses due <br />to water pumped from these ponds for dust control purposes. The maximum surface area of <br />exposed water at the quarry in the ponds has been estimated as 4.7 acres, as shown on the <br />attached Figure 1. Net evaporation from the ponds has been estimated at 3.54 acre-feet per <br />acre per year. The estimated amount of water that will be pumped for dust suppression <br />purposes from the ponds on the site has been estimated at 58 acre-feet per year. Table 1 <br />indicates the monthly evaporation and pumping amounts result in a total annual depletion <br />amount of 74.64 acre-feet. Metered pumping stations are located at the East Pond, North <br />Pond, and Duck Pond and these pumping stations are currently in compliance with the <br />Amended Measurement Rules. <br />Prior SWSP approvals included depletions due to moisture loss in the mined product; however, <br />the SWSP dated July 28, 2014 accepted the results of a ground water investigation that was <br />performed that indicated the mined product lies above the water table. This SWSP will also <br />accept the claim that the mined product lies above the water table; however, Section 6.3 of <br />the Technical Memorandum dated December 31, 2013, indicates that the Codell Sandstone <br />may include ground water, but such ground water may not be tributary to the Arkansas River. <br />This claim that ground water in the Codell Sandstone may be nontributary was repeated in <br />the December 31, 2013 Letter Report and appears to be based on an incorrect interpretation <br />of nontributary that associates the depletion volume with the volume of stream flow of the <br />Arkansas River. Nontributary ground water is defined in 5 37-90-103(10.5). C.R.S., as ground <br />water where the withdrawal will not, within 100 years of continuous withdrawal, deplete the <br />flow of a natural stream at an annual rate greater than one-tenth of one percent of the <br />