2019-02-15_PERMIT FILE - M2018060

• Permit No: M2018060
• IBM Index Class Name: PERMIT FILE
• Doc Date: 2/15/2019
• Doc Name: Adequacy Review Response
• From: Applegate Group
• To: DRMS
• Email Name: ECS
• Media Type: D
• Archive: No

Eric Scott
RE:Response to Preliminary Review of a 112 Construction Materials Reclamation Permit Application Package,
Tollgate Pit,File No.M-2018-060
February 15, 2019
Page 4 of 7
There are several other wells that are located on or near the proposed permitted area but have not been
included in the groundwater monitoring plan for the following reasons:
• Well#2 was the monitoring hole that was converted into the monitoring well identified as#3(MW-
16).
• Wells # 4, 5, 6 are irrigation wells and thus are not ideal for monitoring well use. Their plotted
location from the Division of Water Resources data is based on quarter sections and thus is not
exact so they are likely not truly located in the place identified in Exhibit B.
• Well#8 was the monitoring hole that was converted into the monitoring well identified as well#23
(MW-17).
• Wells #7 (MW-17), #21 (MW-3) and #25 (MW-2) are located on property owned by Aggregate
Industries and readings are reported as part of the WW Farms gravel pit(DRMS Permit No.M-99-
098).
• Well #22 was the monitoring hole that was converted into the monitoring well identified as #23
(MW-20).
Groundwater Monitoring/Mitigation Plan comments:
At this time, Bucklen Services is proposing to monitor only the three wells listed in the groundwater
monitoring plan (MW-15, MW-16 and MW-20). Note that MW-15 is currently unusable but will be
repaired or replaced prior to the commencement of mining. If additional readings are needed to supplement
the Tollgate Pit monitoring wells,readings from the WW Farms Pit monitoring wells(MW-2,MW-3 and
MW-17)can be obtained from AI's regular reports.
Wells MW-15, MW-16 and MW-20 were installed by Aggregate Industries in January 2008 and were
continuously monitored by Aggregate Industries until June 2018. This period of continuous readings
exceeds the five consecutive quarters requirement. This data was submitted with its regular reports for the
WW Farms Pit and will serve as the baseline groundwater data for the Tollgate Pit.Additional data collected
by Bucklen prior to mining will serve as a supplement to this baseline data.
It has been noted that the 30-day notification period to evaluate/take action and notify the DRMS in the
event of a complaint of an impacted well is no longer standard practice for the DRMS.Bucklen will commit
to no more than 5 working days to notify the DRMS,in writing,with the complaint and an action plan.
The operator acknowledges that it will be responsible for mitigation of any licensed well that the DRMS
determines has been adversely impacted by the operator's mining activities, regardless of the well's use
prior to mining activities.
EXHIBIT L—Reclamation Costs(Rule 6.4.12):
Table 2 is an updated cost estimate for the reclamation on the Tollgate Pit site. The major phases of
reclamation will be minimal grading,top soiling and seeding and the construction of the armored inlet/outlet
structures. Since the site will be mined with 311:IV slopes in all areas, no major grading will be required,
only minor blade work on the slopes,around the perimeter of the mine and in the topsoil stockpile location.
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