2019-01-11_REVISION - M2014043

• Permit No: M2014043
• IBM Index Class Name: REVISION
• Doc Date: 1/11/2019
• Doc Name: Adequacy Review Response
• From: Environment, Inc.
• To: DRMS
• Type & Sequence: TR1
• Email Name: JLE
• Media Type: D
• Archive: No

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LARRY E.O'BRIAN 7985 VANCE DRIVE,SUITE 205A
FOUNDER ARVADA,COLORADO 80003
STEVAN L.O'BRIAN 303-423-7297
PRESIDENT FAX [phone]
January 7, 2019 R10111van
�' VMr. Jared Ebert JAN 11 2019
Division of Reclamation, Mining & Safety DIVISION OFRECLAMA11ON
1313 Sherman St., Suite 215 KNING AND SgFEly
Denver, CO 80215
Dear Jared;
RE: Albert Frei and Sons, Inc.
Hatchery Pit - M-2014-043
Technical Revision 01 adequacy response 01
On behalf of my client Albert Frei and Sons, Inc., I am responding to your
adequacy review letter dated October 3, 2018. I have included your review points that
need to be addressed in the order presented so the questions and answers will be in the
same document for easy reference. Also included are copies of the revised Ground Water
mitigation plan, the Design plans for the compacted liner and french drain and a copy of
the most recent monitoring well data table.
Pit dewateri=
The proposed revision request to change the mining and reclamation plan for the Stage 2
area by allowing for dewatering of the site during the mining of this area and installing a clay
liner as opposed to a slurry wall. Mining below the groundwater table in the Stage 2 area was not
to occur until after collecting monthly water level data for one year and a quarter and prior to the
installation of the slurry wall. Also, dewatering of the area was not contemplated in the original
permitting process for the installation of the plant site and the first phase of mining in the Phase 2
area. According to the information in TRO1, it appears dewatering has already occurred within
the Phase 2 area and is occurring presently and appears to have already impacted the groundwater
levels in the area. Upon a closer review of the CTL and Deere and Ault drilling data submitted
with the original application, groundwater levels ranged from 5,071 feet on the west side near the
plant site to 5,083 feet on the east side of the site. Based on the September 4, 2018 monitoring
data the water levels on the east side (MWO1, 02 and 03) were reported to be at an average level
of 5,073.591 feet. This is a fairly significant drop. Please address the following:
1.) Based on the Division of Water Resources well permit data a domestic well (Permit No.
5350) is located just north of the plant site adjacent to the two monitoring wells owned by