2019-04-17_REVISION - M1974086 ‎(3)‎

• Permit No: M1974086
• IBM Index Class Name: Revision
• Doc Date: 4/17/2019
• Doc Name: Adequacy Review Response
• To: DRMS
• Type & Sequence: AM4
• Email Name: ECS
• Media Type: D
• Archive: No

AM04 RECEIVED
APR 17 2019
ECS
DfVkl; N OF RECLAW-noN
MWIW AND SAFETY
Greg Lewicki And Associates, PLLC
3375 W.Powers Circle Phone: [phone] Fax[phone]
Littleton,CO 80123 E-mail:[e-mail]
April 15, 2019
Eric Scott
Colorado Division of Reclamation, Mining, and Safety
1313 Sherman St, Rm 215
Denver, CO 80203
RESPONSE TO: Adequacy Review of a 112 Construction Materials Reclamation Permit
Amendment Application Package AM04,Ralston Quarry,Permit No. M-1974-086.
ADDENDUM 1 —Conditional Approval Request
Asphalt Paving Co., Inc. is requesting that the Colorado Division of Reclamation, Mining, and
Safety approve the currently under-review amendment to the Ralston Quarry reclamation permit.
Attached to this letter are two of the outstanding items requested from CDRMS to address
outstanding adequacy concerns: a revised Map C-2 showing the dewatering pipe route for the
quarry bottom stormwater draining and an invoice documenting the cost of the fencing installed
at the quarry as part of reclamation. The only remaining item, according to discussion with
CDRMS staff, is the Colorado Division of Water Resources letter dated February 11, 2019.
The CDWR letter raised concerns about whether the quarry as proposed intercepts or will
intercept a groundwater aquifer as mining progressed. This concern was raised primarily due to
the presence of water in the bottom of the quarry that was visible in aerial photos of the site.
CDWR is concerned that this water was from subsurface sources.
Asphalt Paving Co. contends, based on their operational experience and a thorough
hydrogeologic analysis of the site by Brierley and Associates,that the only source of water
within the low point of the quarry is stormwater that has drained to the low point. Asphalt Paving
Co. is therefore working to provide CDWR with any and all necessary information to
demonstrate the fact that the water found in the quarry bottom is all surface water from storm
events.
The purpose of the amendment was to incorporate ground into the affected area that had been
disturbed by a slide on the west side of the permit. Approval of the amendment is needed to
conduct the repairs and reclamation in the slide area. The surface water/ground water questions
being worked through with CDWR are unrelated. APC requests that CDRMS approve the
amendment with the following condition:
The applicant will satisfy CDWR concerns as expressed in the February 11, 2019 letter, and
submit a technical revision to the permit containing CDWRs satisfaction once it is achieved.
Ralston Quarry AM-04 1 Grr}LewiaAi and 1ss<u fates PLL('