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<br /> 8/12 <br />samples will be collected and analyzed for similar constituents as groundwater but <br />there are differences between the two. Please provide separate tables for groundwater <br />and surface water analytes to include the regulatory concentration for each analyte in <br />each of the tables. <br /> <br />Response: The analyte list tables are separated as requested as Tables 2.7.4.1-1 and <br />2.7.4.1-2 in Section 2.7.4.1 of Exhibit G. <br /> <br />F. Groundwater Analytes: The analyte list for groundwater needs additional clarification. <br />For example, it appears the Applicant will be sampling for Thallium and Vanadium, but <br />the Regulation 41 column does not indicate they are analytes of concern. <br /> <br />Response: Appendix A to the SAP is corrected to list the groundwater water quality <br />regulations for thallium and vanadium. <br /> <br />G. Exceedances: There is no discussion on how potential exceedances will be <br />addressed. Please provide a narrative describing how analyte exceedances will be <br />managed. <br /> <br />Response: In the event of an exceedance, Holcim will implement an Adaptive Management <br />Plan as described in Section 2.7.4.1 to modify mitigation measures. <br /> <br />H. Changes: Please acknowledge any changes to the analyte list or SAP/QAPP will be <br />completed through the submission of a TR. <br /> <br />Response: Holcim commits to completing any changes to the analyte list or SAP/QAPP <br />through the submission of a TR. <br /> <br />I. QA/QC Samples: The SAP only mentions duplicate samples will be collected during <br />sampling. However, in the QAPP Section 5.1, the third bullet indicates a more <br />extensive list of QA/QC samples will be collected. The number and type of QA/QC <br />samples needs to be clarified. <br /> <br />Response: The text in the QAPP is revised to reflect the types of QC samples collected, <br />duplicates and field equipment blanks. <br /> <br />6.4.8 Exhibit H- Wildlife Information <br /> <br />29. Wildlife Impacts: The DRMS received a comment letter (enclosed) from Colorado Parks <br />and Wildlife (CPW). The letter acknowledges a meeting and site visit on October 19, <br />2023, which was after the receipt of this amendment application. The CPW letter provides <br />a bullet list of eight recommendations. Pursuant to Rules 3.1.8 and 6.4.8(2), please <br />provide a response to each of CPW’s eight recommendations. <br /> <br />Response: Section 2.8.10 in Exhibit H addresses CPW recommendations. On January 10, 2024, <br />Ms. Cassidy English, CPW SE Regional Land Use Coordinator, participated in a virtual meeting <br />with Holcim (US) Inc. and EAI. Ms. Cassidy clarified that the comment letter d id not contain <br />mitigation directives and requirements but rather provided mitigation recommendations that may <br />be implemented to avoid and minimize impact to wildlife. <br /> <br />• Avoid construction/extraction activities between November 1 and April 30 in order <br />to minimize displacement of wintering bighorn sheep, mule deer, elk and <br />pronghorn from the project area. For the exploratory phase of the project, CPW <br />recommends all work be completed outside the winter season.