2020-05-08_PERMIT FILE - M2020007

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ENVIRONMENT, INC. PAGE 7 L.G. EVERIST, INC. - RAGSDALE RESERVOIR ADEQUACY RESPONSE ❑1 MAY 6, 2020 The reclamation plan maps state that if the backfilled areas are not reclaimed to approximate original grade for cropland, they will be backfilled to at least two feet above groundwater and reclaimed as rangeland. The provision for reclamation as range- land is not found in the text of the reclamation plan. Please edit as needed for consistency. I have changed the notes on the Reclamation Maps to remove the "as rangeland". The owners plan to use the backfilled areas for agriculture crops no matter how full they are filled. EXHIBIT G - Water Information (Rule 6.4.7) : Rule 3 . 6 . 1 (1) of the Minerals Rules and Regulations of the Colorado Mined Land Reclamation Board for the Extraction of Construction Materials states : "Disturbances to the prevailing hydrologic balance of the affected land and of the surrounding area and to the quantity or quality of water in surface and groundwater systems both during and after the mining operation and during reclamation shall be minimized..." To address these concerns, a Groundwater Mitigation Plan was provided by the operator to supplement the required information provided for Exhibit G. After reviewing the provided information DRMS has the following comments and additional requirements . In the first paragraph of the "Mitigation Trigger" section, the last sentence states that mining will start in unlined areas, however Phases 1 and 2 are shown to be slurry wall lined, so this statement is a bit unclear. Please revise as needed. Please also acknowledge that DRMS requires a minimum of five quarters of groundwater level monitoring prior to dewatering or groundwater exposure at the site . I have made a minor revision to the wording in the paragraph you are referring to above, to make it clear what is proposed and I have revised Exhibit G for the record. Mining will start in Phase 1-A, the first unlined area. The material will be moved to Phase 3 for storage and processing. Monitoring began in October 2019, so by January 2021 we will have 5 quarters of data available. The groundwater levels in MW#1 are currently an average of 17.5 feet below the surface, so Mining can begin if needed on Phase 1A in the gravel that lies 2 feet above the water table until the 5 quarters have been collected to avoid exposing ground water. Some nearby wells referred to in Table G-1 (Permits 195505, 38703 , and 25007-F-R) are not shown on the provided figure for G-1 or Exhibit C existing conditions/structures . Please add these wells or explain why they aren' t relevant . Thank you for finding those inconsistencies. I have spent time reviewing the well list again and have found that there were some corrections that needed to be made. All the details are listed below, in answer to your comment (2nd down from here) which starts, "DRMS acknowledges the difficulty in establishing...."