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DRMS Adequacy Comment Response <br />DRMS TR09 Adequacy Review #3 Comments Rationale TR09 Reference and Page Numbers <br />AR1 <br />Exposure of, and any consumptive use of, groundwater in the <br />proposed Satellite South Pit is contingent on SEO issuance of a well <br />permit and substitute water supply plan for the proposed activity. <br />Have these permits been applied for at this time, and if so, have they <br />been issued by SEO? If the permits are not yet issued, is there an <br />estimated timeframe for approval/issuance? <br />Holcim understands that exposure of and consumptive use of groundwater is <br />contingent on SEO issuance of a well permit and subsitute water supply plan. <br />Holcim is preparing an augmentation plan application, as well as SWSP and well <br />permit applications. Holcim is still in the process of finalizing technical details <br />associated with the applications and has not yet identified a specific filing date; <br />however, Holcim anticipates the augmentation plan application will be filed in <br />2024, with the SWSP and well permit applications to be submitted <br />contemporaneously. In any event, Holcim will not mine into and deplete <br />groundwater without a pending augmentation plan and associated SWSP and <br />well permit submissions. <br />The TR09 text in Exhibit D has been updated accordingly. <br />Exhibit D: Groundwater Management <br />Subsection. p. 4. <br />AR2 <br />TR9 states that a permanent augmentation plan is being pursued for <br />the anticipated groundwater exposure in the Satellite South Pit area. <br />Has this augmentation plan been filed in water court yet? If not, what <br />is the anticipated filing time frame? What permanent exposed surface <br />area and capacity are being pursued through this augmentation plan <br />and whose water rights will be utilized for this proposed plan? <br />Please refer to the response to comment AR1. Holcim is still in the process of <br />finalizing technical details associated with the augmentation plan application. The <br />augmentation plan will use water rights owned by Holcim and jointly owned by <br />Holcim and the Town of Morrison, as well as other leased water rights. <br />The TR09 text in Exhibit D has been updated accordingly. <br />Exhibit D: Groundwater Management <br />Subsection. p. 4. <br />AR3 <br />Continued groundwater level monitoring will be required until a well <br />permit and substitute water supply plan have been issued for the site. <br />Existing groundwater monitoring wells may not be abandoned without <br />alternate approved provisions for monitoring, should it be required, <br />until either the permanent augmentation plan has been approved, or <br />mining has progressed beyond the depth of the existing wells. <br />Holcim recognizes the need to monitor groundwater levels downgradient of the <br />South Quarry until they acquire an approved augmentation plan. To streamline <br />monitoring requirements, the side-gradient and up-gradient monitoring wells, <br />MW-2019-02 and MW-2019-03, will be abandoned. The most downgradient <br />monitoring well, MW-2019-01, will continue to be monitored until the <br />augmentation plan is approved. This monitoring frequency will be reduced to <br />quarterly. <br />The TR09 text in Exhibit G has been updated to address this change. <br />Exhibit G: Groundwater. P. 19. <br />Item # <br />Holci-WCR, Inc. Response <br />ADEQUACY REVIEW (AR) Letter #1 November 7, 2023 - TR09 Text <br />1